The “broad-brush tarring of the entire [nonprofit] sector is contrary to the evidence base and has been criticised by the NPO sector,” the Global NPO Coalition on FATF stated in its April 29 submission on revisions to Recommendation 8.

In addition, the Coalition stated, “R8 has had numerous unintended consequences as several governments have tightened rules on the NPO sector beyond what is required under R8. Cases of overregulation include difficulties faced in accessing and distributing financial resources, cumbersome registering and license laws, and increased state survillance and regulation of the sector without any targeted and/or risk based approach.”

The Coalition suggested changing the existing language in R8 that NPOs are “particularly vulnerable” to the following: “Where some non-profit organisations are found to be at risk, countries should address identified risks with a proportionate and targeted approach, consistent wtih countries obligations to respect fundamental human rights and international humanitarian law.”

The Financial Action Task Force openened the Interpretive Note (IN) to R8 for revision late last year. In comments submitted on the IN, the Coalition asked that R8 itself also be revised. FATF agreed to accept suggested revisions and opened a brief public comment period following its consultation with NPOs in Vienna in March. The revisions to both R8 and the IN are expected to be announced at FATF’s June plenary meeting.

If your country is a member of FATF (see list of members here), please contact your delegation and ask them to support the Coalition’s proposed revisions. If your country is not a member of FATF, it is likely to have a point of contact with FATF from the mutual evaluation process. Non-member states can voice their support for our proposals by contacting FATF or the FATF regional bodies (on the list of “Associate members” here).