A report on the risks non-profit organizations (NPOs) face from terrorist abuse was released in June 2014 by The Financial Action Task Force (FATF). The FATF, an inter-governmental body that makes recommendations for country level anti-terrorist financing policy, used over 100 case studies derived from governments and open sources to map vulnerabilities for terrorist abuse present in the NPO sector. However, civil society groups argue that the FATF has overstated the problem of terrorist abuse of NPOs, and that this overstatement may have serious consequences as countries develop policies to combat abuse.

The report, Risk of Terrorist Abuse in Non-Profit Organizations, may be used by the FATF and its member states to help guide an upcoming revision of their 2013 Best Practices document on regulation of the NPO sector to prevent terrorist financing. The forthcoming Best Practices guidance will revise the previous version which many civil society groups have argued is overly broad and an invitation for abuse. These organizations argue that some countries have used FATF recommendations as an excuse to clamp down on democracy and human rights organizations.

The FATF report follows recommendations sent by the Charity & Security Network and Human Security Collective in February. These comments called for the following considerations to be made during the formulation of the Risk of Terrorist Abuse in Non-Profit Organizations:

  • FATF should distinguish between potential risk and actual abuse

  • Typologies should be based on analysis of evidence that classifies clusters of similar cases

  • A variety of strategies are needed to address a variety of types of abuse

  • Typologies should recognize the diverse structures and functions of NPOs

  • FATF should avoid an overbroad definition of terrorist financing

  • Risk mitigation procedures undertaken by the NPO sector should be recognized

  • Impacts on the NPO sector must be minimized

A formal response to the FATF’s report from the Charity & Security Network and other groups will follow in the coming weeks.