“Global NPO Coalition on FATF calls for revision of the FATF Recommendation 8”, 15 Jan 2016

The undersigned nonprofit organizations (NPOs), representing 123 organizations in 46 countries, coming from different backgrounds (human rights, social service, donor community, etc.) call on the FATF to open a process to revise Recommendation 8.  Since Recommendation 8 provides the basic standard, it is necessary to integrate and ensure coherent application of the risk-based, proportionate and targeted approach that the Interpretative Note and Best Practice Paper further elaborate.  Further, Recommendation 8 is currently based on the unproven assumption that the entire NPO sector is "particularly vulnerable" to terrorism financing abuse: 1. This is not in line with the FATF-endorsed risk-based approach.  It misleads governments to apply heightened measures to the entire NPO sector that result in over-regulation of the sector…2. There is no evidence that NPOs are particularly vulnerable compared to other sectors.  Recommendation 8 fails to recognize that the vast majority of the millions of NPOs pursue legitimate charitable activities and that abuse for terrorist financing is rare…The need to revise the standard is also recognized by the UN special rapporteur on the promotion and protection of human rights and fundamental freedoms while countering terrorism…