Ensuring that financially excluded or underserved groups have access to regulated financial services helps to strengthen the implementation of AML/CFT measures. The FATF Standards also helps protect the non-profit sector from abuse for terrorist financing.  Using the risk-based approach, these measures should not disrupt or discourage legitimate non-profit activities.

In February 2021, the Financial Action Task Force (FATF) launched a project to study and mitigate the unintended consequences resulting from the incorrect implementation of the FATF Standards, including de-risking, financial exclusion and undue targeting of NPOs.

The first phase of this work was a stocktake, to consolidate previous analysis of these phenomena by FATF and other stakeholders, including expert bodies, in order to identify and understand to what extent, and in what manner, these unintended consequences are occurring. The results of this work are captured in a High-Level Synopsis of this Stocktake . The high-level synopsis summarises a longer stocktake report, which itself brings together existing knowledge from various sources as a basis for policy decisions. As such, it is focused on a small number of topics of greatest concern, and is not an exhaustive academic analysis of these phenomena. Nor does it set out a formal FATF position and conclusion on any of them.

The stocktake supported further consideration of policy options for the FATF. In March 2022, the FATF Plenary announced that it had completed its work to identify and analyse unintended consequences of the FATF Recommendations. It agreed to refer the substantive work to the relevant FATF Working Groups, which will scope out and refine how FATF can mitigate the unintended consequences of FATF’s Standards.

The FATF will continue to engage with external stakeholders as this work develops and appreciates the significant input already received to inform this project. See the documents below for more information about FATF's existing information on financial inclusion and NPOs.  

In October 2023, the FATF Plenary agreed on amendments to the FATF Recommendations to protect non-profits from abuse for terrorist financing, at the same time, the FATF updated its best practices paper.  

To assist assessment teams in upcoming mutual evaluations, the FATF compiles input from non-profit organisations (NPOs) and other civil society organisations on money laundering and terrorist financing risk and context.

For NPOs—as defined by the FATF—this could include information related to the implementation of risk-based measures to protect the sector from potential terrorist financing abuse. Similarly, input could include experiences of the application of the risk-based measures set out in Recommendation 8, or suggestions to help the assessment team identify which NPOs to gather more input from and/or interview during the on-site visit.

In order for assessment teams to consider input for upcoming assessments, please provide your input on a jurisdiction to contact@fatf-gafi.org no less than two months prior to the indicated onsite date. Please refer to the FATF mutual evaluation calendar for upcoming assessments and onsite dates.

Please note that any information provided to the FATF Secretariat will be shared with the assessment team, the assessed country, and external reviewers and the source of information will be identified. As assessors have huge volumes of material to review, please provide information in a succinct manner and in a format that mirrors the FATF Methodology . There is no mechanism under our FATF Procedures to provide feedback about how, or if, information received has been taken into account.