Are NGOs subject to AML / CTF?
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-state registers) and require regulated banks to apply EDD to NPO customers operating in conflict zones or high-risk jurisdictions.