Conduct relevant outreach with a multitude of stakeholders, including NPOs, government, financial institutions, regulators and regional/international bodies.
Continuous engagement on the issues at stake is key. This applies to both NPOs as well as to governments and FATF-Style Regional Bodies.
Governments are assessed on their outreach to the NPO sector and poor outreach often means a poor mark on the Mutual Evaluation. Make sure the ‘no outreach to NPOs’ = ‘poor rating on Recommendation 8’ message is driven home to the government.
For NPOs, in terms of capacity, it is ideal is there is an umbrella body or a coalition working on the issue, raising awareness in the sector and spearheading the advocacy work. NPOs should seek to engage with relevant government departments, the Financial Intelligence Unit, banks, and regulators. Engagement helps better the understanding of varying mandates, and helps in the working towards a solution.
BEST PRACTICE
In Kyrgyzstan and Tunisia, for example, good working relations have been established between NPO and government representatives, and there is sustained dialogue and engagement.
The Netherlands: A formalized roundtable process, with the Ministries of Finance and Foreign Affairs, the Financial Intelligence Unit, NPOs and banks to discuss financial access issues faced by NPOs as a result of AML/CFT regulations, among others.
Multi-stakeholder dialogue: This is often the best way of understanding different mandates (security, development, humanitarian principles, financial integrity, regulation, risk mitigation) and engaging effectively on the issues. It is particularly pertinent when trying to solve financial access (bank derisking) issues facing NPOs.
RESOURCES:
Read here on entry points for NPOs, for engagement in the FATF evaluation process and beyond.
