On June 28, 2013 the Financial Action Task Force (FATF) released an updated guidance for governments implementing financial sanctions in line with the United Nations Security Council resolutions relating to curtailing terrorist financing.  FATF’s Recommendation 6 calls on governments “to freeze, without delay, the funds or other assets” of entities designated by the UN Security Council under the al-Qaida/Taliban sanctions regime (Security Council Resolutions 1267/1989) and Security Council Resolution 1373.

According to the FATF, the implementation of these procedures requires co-ordination between a country’s financial, intelligence, and law enforcement officials.  However, to foster “widespread support for an effective counter-terrorist financing regime, countries must respect human rights, respect the rule of law, allow due process, recognize and protect the rights of bona fide third parties” in these measures.

To minimize the burdens imposed by these rules, the guidance suggests governments develop a communications plan explaining its assets freezing regime for their country’s private sector. “[C]ountries need to be aware of the impact compliance with these laws has on their business activities, and seek to minimize the costs of compliance as far as possible.” At the same time, no such concerns are made for reducing the impact compliance with these measures have on humanitarian programs carried out by the non-profit sector, a sector described as “high-risk.”