The Global NPO Coalition on FATF submitted comments to the United National Special Rapporteur on the promotion and protection of human rights and fundamental freedoms while countering terrorism regarding “Soft law and informal lawmaking in the global counter-terrorism architecture.” Focusing on the Financial Action Task Force (FATF), the comments note the ways in which country-level implementation of FATF’s counterterrorist financing standards has negatively affected nonprofit organization (NPOs) and the constructive engagement between the coalition and FATF that led to revision of the NPO standard in 2016. The comments noted the lack of oversight mechanism for ensuring human rights and “humanitarian obligations” are considered during implementation of the FATF’s recommendations. The conclusion finds that “[e]stablishment of best practices for clear internal policies or rules for engagement and transparency for such bodies would increase the potential for engagement and thus, incorporation of human rights and humanitarian considerations into their proceedings.”
In addition, the coalition makes the following recommendations relating to FATF:
- Open plenary meetings to the public and publish the agenda prior to the sessions;
- Establish clear processes and standards for engagement with the nonprofit sector and other stakeholders?;
- Include experts on human rights and humanitarian law in FATF evaluation teams and on the Secretariat staff;
- Provide training on the nonprofit sector and human rights and humanitarian law for FATF staff, FSRBs and evaluation teams;
- Require clear terms of transparency and engagement for civil society by FSRBs, and then national governments.