Joint Comments on Draft Financial Action Task Force
The Financial Action Task Force (“FATF”) Best Practices Paper (“BPP”) on Combating the Abuse of
Non-Profit Organisations (Recommendation 8) was first written in 2002, in the wake of the September 11
terrorist attacks. The purpose of the BPP is to set out specific examples of good practice which may,
among other benefits, assist countries and non-profit organisations (“NPOs”) in their implementation and
adherence of Recommendation 8, as well as assist financial institutions in the proper implementation of
the risk-based approach when providing financial services to NPOs, and guide donors who are providing
funding to NPOs.
Since its inception, a limited update of the best practices paper was conducted in 2013, followed by a
report on Risk of Terrorist Abuse in Non-Profit Organisations in June 2014, which, along with additional
input and examples of best practice from governments and the private sector, led to further revisions. On
April 28, 2015, 70 NPOs from 28 countries submitted joint comments on the current draft.
These joint comments from NPOs emphasize that the BPP’s primary purpose should be to “provide
guidance for governments” and support outcomes that do not over-regulate NPOs. The comments advise
that the BPP should be cognizant that the overall risk of terrorist abuse of the NPO sector is actually very
low, both in numbers and geography. By implementing these recommendations, the BPP will be more
persuasive among stakeholders, and allow them to take appropriate risks without fear of drastic
enforcement measures