What does FATF Recommendation 8 mean for our NGO?

FATF is the Financial Action Task Force — an intergovernmental body that sets global standards for combating money laundering and terrorist financing. FATF Recommendation 8 (R.8) specifically addresses Non-Profit Organisations.

Key changes affecting your CSO:

1. NPOs are no longer classified as “Listed Businesses” under the Proceeds of Crime Act — this removes burdensome obligations that previously applied
2. FIUTT’s role changed from “Supervisory Authority” to “Oversight Authority” for NPOs — it now provides guidance using a risk-based approach, focusing on NPOs identified as at risk
3. Beneficial ownership obligations now apply — you must identify and verify all controllers
4. Annual Returns are now mandatory for all NPOs

For most small, community-based CSOs with limited income and low-risk activities, the practical impact is manageable. The key is ensuring your registration is current, your controllers are identified, and your Annual Returns are filed on time.