In February 2021, the FATF launched a major review of the unintended consequences  resulting from the incorrect implementation of the FATF Standards, including the undue targeting of Non-Profit Organisations (NPOs) and other areas, such as de-risking and financial exclusion. As a result of this review, and to further address the unintended consequences related to the FATF Standards' impact on NPOs, the FATF introduced a new procedure in 2025 to identify, assess and address such unintended consequences.

In alignment with the amended 6th Round Rules of Procedure (Rule 38 bis), MONEYVAL has established a process for handling reports related to a member’s implementation of obligations regarding NPOs that may lead to unintended consequences, as set out in the FATF Procedures. This procedure enables countries, the International Monetary Fund (IMF), and the World Bank to raise concerns about a country’s misapplication of the Standards when it disrupts legitimate NPO activities.

How can NPOs and civil society organisations provide input into FATF Mutual Evaluations?

MONEYVAL has created a channel to provide input during mutual evaluation, and mutual evaluation teams meet with civil society representatives.

To assist teams in upcoming mutual evaluations, MONEYVAL compiles and shares input from NPOs and other civil society organisations on money laundering and terrorist financing risks and context with the FATF.

For NPOs (as defined by the FATF), this input might include:

  • Information related to risk-based measures adopted to protect the sector from potential terrorist financing abuse.
  • Experiences regarding the application of risk-based measures under Recommendation 8.
  • Suggestions to help assessment teams identify NPOs for further engagement or interviews during the on-site visit.

To ensure your input is considered for upcoming assessments, please send information related to a jurisdiction to [email protected], no less than two months prior to the indicated onsite date.

Please note that any information provided to the MONEYVAL Secretariat will be shared with the assessment team, the assessed country, external reviewers and the FATF and the source of information will be identified. As assessors have large 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 the current FATF or MONEYVAL Procedures to provide feedback about how, or if, information received has been taken into account.

For more information or to provide input, NPOs are encouraged to contact MONEYVAL through its dedicated channel ([email protected]).