FATF Plenary February 2026
The February 2026 Financial Action Task Force (“FATF”) Plenary, held in Mexico City from February 9-13, focused on addressing evolving illicit finance risks, including cyber-enabled fraud and virtual assets, while advancing its global anti-money laundering, anti-terrorism financing, and counter-proliferation financing (AML/CFT/CPF) framework. These developments are particularly relevant for charities and not-for-profit organizations (NFPs), especially those operating internationally, as they continue to face compliance challenges in an increasingly complex regulatory environment.
The FATF is an inter-governmental body that sets international standards to combat money laundering, terrorist financing, and other threats to the integrity of the international financial system. Its 40 Recommendations establish a comprehensive framework for countries to implement effective AML/CFT measures, supported by interpretive notes and guidance.
At this Plenary, the FATF advanced its work on identifying and responding to emerging financial crime risks. In particular, it approved a new paper on cyber-enabled fraud, highlighting the growing scale and sophistication of fraud facilitated by digital technologies. The FATF signalled that combating fraud will be a key priority in the coming years, with an emphasis on leveraging technological innovation to detect, prevent, and respond to such activity.
The FATF also approved two upcoming reports on risks related to cryptocurrencies and other digital assets. One report looks at businesses operating in countries with weaker regulation, and how this can be used to avoid oversight. The other focuses on newer types of digital payments that are more difficult for regulators to track. Overall, this work reflects the FATF’s efforts to keep up with changes in technology and address new risks as they arise.
In terms of compliance and monitoring, the FATF updated its list of jurisdictions under increased monitoring (commonly referred to as the “grey list”), adding Kuwait and Papua New Guinea due to identified deficiencies in their AML/CFT/CPF regimes. The FATF also updated its statement regarding Iran as a high-risk jurisdiction subject to a call for action to “protect the international financial system.” These updates are relevant for charities and NFPs conducting cross-border activities, as they may impact risk assessments, due diligence obligations, and financial access in affected jurisdictions.
The Plenary also adopted mutual evaluation reports for Austria, Italy, and Singapore under a new, more results-focused assessment framework. Countries will be expected to implement time-bound action plans to strengthen their systems. This approach may influence how regulators assess compliance expectations, including for charities and NFPs.
For charities and NFPs, these developments reinforce the importance of maintaining robust compliance frameworks, particularly in relation to fraud prevention, virtual asset exposure, and cross-border activities. Organizations should continue to monitor FATF updates, reassess geographic and operational risks, and ensure that internal controls and due diligence processes remain aligned with evolving international standards.
UN Human Rights Council Calls for Input on Sanctions and Access to Health: Relevance for Charities and NFPs
The Human Rights Council (“HRC”) Advisory Committee has issued a call for input to inform an upcoming study on the impact of unilateral coercive measures (“UCMs”), commonly referred to as sanctions, on the right to health of individuals in vulnerable situations. The study will be presented at the HRC’s 64th session and could have implications for charities and not-for-profit organizations (NFPs) engaged in international operations, particularly in jurisdictions subject to sanctions regimes.
The Advisory Committee, a body of experts that provides research-based advice to the HRC, has been tasked with preparing an in-depth review of how UCMs affect access to healthcare. This work is being carried out in collaboration with the UN Special Rapporteur on the negative impact of unilateral coercive measures.
The study will examine several key issues, including how sanctions may affect access to medicines and healthcare services, the mechanisms through which these impacts arise, and the short- and long-term consequences for vulnerable populations, particularly women and children. It will also consider the broader social and economic costs of such measures, as well as identify best practices to mitigate adverse effects.
As part of this process, the Advisory Committee is seeking input from stakeholders, including civil society organizations. Submissions may address, among other things, gaps in available data, practical challenges encountered in delivering healthcare or humanitarian assistance, and examples of measures that have helped reduce negative impacts in sanctioned environments.
For charities and NFPs operating internationally, particularly those providing humanitarian or health-related services, this initiative presents an opportunity to contribute to the development of international policy in this area. Organizations with experience navigating sanctions-related restrictions may wish to consider providing input to help ensure that the operational realities of the sector are reflected in the study.
Submissions must be sent by email to [email protected] by April 30, 2026, and may be submitted in English, French, or Spanish.