Non-profit organisations
Following the terrorist attacks in 2001, initiatives were taken by a number of international stakeholders to identify the threats and vulnerabilities associated with terrorism. Based on the assessments of risks connected with terrorism, the FATF formulated new measures in 2001 (the FATF IX Special Recommendations), where one of the designated areas of focus was the non-profit sector (Special Recommendation VIII). This was due to the fact that the non-profit sector is vulnerable to abuse for the purposes of financing of terrorism.
It is to be stressed that the FATF recognises the importance of the non-profit sector and appreciates its efforts. The measures foreseen by the FATF concerning the NPO sector are therefore to be implemented whilst simultaneously protecting the values inherent to its purpose and activities and without disrupting them. The aim of setting out standards to protect the non-profit sector from terrorist financing abuse is to cut terrorists off from their sources of financing and create an environment which would not be susceptible to abuse. On the other hand, it further envisages protecting the sector itself, since potential risks encountered could lead to losing its credibility and trust in the eyes of the public, which are key to its role in society.
The measures envisaged by the FATF Standards in respect of NPOs firstly aim at increasing the capacity of NPOs themselves to identify the risks they are facing and to avoid potential abuse. It has, however, been identified that given the complexity of the issue and the ingenious ways criminals manage to hide their illicit activities, it is not sufficient to rely only on the sector in this matter. Accordingly, Recommendation 8 of the FATF 2012 Recommendations (as amended up to 2023) requires state authorities to maintain a comprehensive understanding of the NPO sector in the country, its characteristics and corresponding risks, as well as to designate an authority responsible for supervision to an extent sufficient to identify potential illicit activities.
In order to provide countries with guidance regarding the implementation of measures concerning NPOs, the FATF has issued a series of Best Practices papers and Guidance documents, updated to reflect current developments. The most recent update in 2023 was based on extensive consultations with the NPO sector, enabling the FATF to better identify the potential areas of concern and to target more precisely the issues presenting practical difficulties.
Reference documents
- FATF (2025) new procedure to address unintended consequences affecting Non-Profit Organisations
- FATF Best Practices (2023) – Combating the Abuse of Non-Profit Organisations (Recommendation 8)
- FATF Guidance (2021) – Risk-Based Approach to the Non-Profit Sector
- FATF Report (2014) – Risk of Terrorist Abuse in Non-Profit Organisations
- FATF Best Practices (2015) – Combating the Abuse of Non-Profit Organisations (Recommendation 8)
Relevant Council of Europe websites
Conference of the Parties (COP) to the CETS 198
