Question 1

Are NGOs subject to AML / CTF?

Accepted Answer

NPOs are not generally classified as "obliged entities" themselves but are recognised by FATF Recommendation 8 as a sector vulnerable to terrorism-financing abuse. Many regimes therefore impose specific transparency and registration obligations (UK Charity Commission, US IRS Form 990, EU member-s...

Question 2

Why are charities a recognised TF risk?

Accepted Answer

Cross-border fund flows, decentralised operations in conflict zones, frequent cash distributions, volunteer-heavy governance, and reputational sensitivity that historically discouraged enquiry. FATF has progressively narrowed Recommendation 8 to focus only on the *subset* of NPOs identified as ac...

Non-profits & charities