Case Study: U.S. Nonprofit Organizations and the FATF Mutual Evaluation Process 2015-16

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Date: 
November 20, 2017
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This case study of the Financial Action Task Force’s (FATF) evaluation of the United States, which took place in 2015-2016, reviews the experience of nonprofit organizations (NPOs) seeking to provide input to the evaluation team and makes recommendations to make the process for stakeholder input more transparent and streamlined. It describes efforts by the Charity & Security Network and Council on Foundations to address the problem of over-regulation of NPOs under U.S. anti-terrorist financing laws. Although the evaluation was conducted under the old FATF Recommendation 8 on NPOs, it took place during a period of expanding engagement between FATF and NPOs about how governments should implement FATF’s risk-based approach. The lessons learned suggest that “FATF and NPOs should identify ways in which stakeholders can better understand the process and establish a common format and process for stakeholders to provide input.” Specific recommendations for both FATF and NPOs are included. The full report is here.