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How Can CSOs Best Interpret and Use the Latest Financial Action Task Force (FATF) Changes for Their Advocacy?

by European Center for Not-for-Profit Law

Published | December 2023

Tackling impacts of counter-terrorism

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This guide advises how to use recommendation 8 of the FATF global actions, focusing on the non-profit sector.

Why read

The guide helps NGOs to navigate through the FATF recommendation on the non-profit sector and explains how to use it for NGOs' advocacy.


In 2021, The Financial Action Task Force (FATF), which leads global actions to tackle money laundering, terrorism, and proliferation financing, initiated a project to scrutinize the limitations and harmful impacts of the flawed implementation of its standards, in particular, Recommendation 8 (R8) on the non-profit sector. In 2023, following a consultation process with stakeholders from the civil society sector and financial institutions, FATF made amendments to R8 striving to address the problem of the over-application of preventive measures to the civil society sector. To best interpret and use FATF’s R8, ECNL has put together a guide for CSOs explaining how and why the recommendations must be interpreted with a critical lens and provides useful paragraphs to quote toward authorities, banks, and other relevant stakeholders. Used effectively, the newly revised FATF standards can help civic society to:

  • Underscore not all organizations are at risk of terrorist financing abuse;
  • Urge governments to meaningfully include and consult civil society when addressing terrorism financing risk;
  • Require banks to have a more nuanced approach to CSOs;
  • Raise awareness and educate themselves and colleagues on how to push back on harmful narratives and restrictions stemming from security and counter-terrorism space.


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