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Version date: 5 July 2019 - onwards

Part 4: Non-Profit Organisations and Assessing Terrorist Financing Risk

61. Recognising the requirements under Recommendation 8 (R.8) to assess TF risks facing those NPOs that fall within the FATF definition, this chapter provides some considerations and good approaches based on jurisdiction experience. The general guidance provided in other parts of this report is also relevant for the assessment of TF risks associated with NPOs. Of particular relevance are the general issues relating to national coordination and stakeholder engagement (included in chapter 1), and the need to maintaining an up-to-date understanding of risk (dealt with in the chapter 5 of this report).

62. In June 2016, the FATF revised R.8 to ensure its implementation is in line with the risk-based approach and does not disrupt or discourage legitimate non-profit activities [These amendments were informed by the June 2014 FATF Report on Risk of Terrorist Abuse in NPOs and the 2015 FATF Best Practices Paper on Combating the Abuse of NPOs.]. The revisions clarified that not all NPOs represent the same level of TF risk, and that some NPOs represent little or no risk at all. Experience shows that jurisdictions continue to face challenges in assessing TF risk in this area due in part to: the large and often diverse nature of the sector, a lack of identification or understanding of those NPOs falling within the FATF definition, and the limited availability of relevant quantitative information or cases.

FATF Requirements on Identifying and Assessing TF Risk Facing NPOs