Prior to its revision in 2016, the Financial Action Task Force's Recommendation 8 referred to nonprofit organizations as "particularly vulnerable" to terrorist abuse. As a result, many countries implemented laws and policies designed to curb this perceived risk. As a result, NPOs have faced increased scrutiny and legal constraints, shrinking the space for charitable work.
A report from Spaces for Change in Nigeria, Closing Spaces for Civil Society and Democratic Engagement in Nigeria, examines the impact of Recommendation 8 on civil society in that country. The first part, Beyond FATF: Trends, Risks and Restrictive Regulation of Non-profit Organisations in Nigeria, is the product of systematic review of that country's legal framework for combating money laundering and the financing of terrorism to understand the connection between Nigeria's implementation of Recommendation 8 and shrinking space for civil society there. The second part, Closing Spaces for Civic Engagement and Civil Society in Nigeria, assesses the effectiveness of these policies and created a database of closed spaces, highlighting 100 incidents of overbroad application of these laws.
"Overall, there may not be explicit linkages between the fulfillment of treaty (international) obligations and the national legislative attempts to regulate the civic space," the report explains. It adds, "But that does not mean the linkages are illusory or non-existent." The report found that there have been consistent restrictions on freedom of expression in Nigeria. Although the language of Recommendation 8 was changed in 2016, Nigerian AML and CFT frameworks "remain significantly unchanged, and continue to put additional obligations (and restrictions) on NPOs," the report found.