- In November 2019, over 40 representatives of nonprofit organizations (NPOs) were trained on FATF Recommendation No. 8 and the risk that the NPO sector could be misused to finance terrorism.
- The training also emerged as a response to Moneyval's findings, the Council of Europe body that periodically monitors Albania's anti–money laundering and counter-terrorism financing framework.
- Subsequent Moneyval assessments have noted improvements, but Albania remains under an ongoing enhanced follow-up process, so the issue remains relevant today.
- From this training stem several concrete preventive measures that any NGO can implement on its own, regardless of the institutional changes that have taken place since then.
In early November 2019, over 40 representatives of non-profit organizations (NPOs) participated in a training organized by the General Directorate of Taxation and, at the time, the Directorate for the Prevention of Money Laundering (DPPPP), on the anti-money laundering and counter-terrorist financing system. The training focused on Recommendation No. 8 of the Financial Action Task Force (FATF) and on the findings of Moneyval, the Council of Europe body that periodically assesses the Albanian framework in this field.
From our daily work, we see that many NGOs treat the anti–money laundering framework as an issue that affects only banks or financial institutions, whereas the FATF specifically views the nonprofit sector as an area of heightened risk for abuse.
Read also: Nonprofit anti–money laundering oversight: how it works today, for the institutional history and Instruction No. 19/2019.
What did the 2019 training cover?
FATF Recommendation 8 and Moneyval's findings
Recommendation No. 8 of the FATF requires each country to identify the non-profit organizations most exposed to the risk of misuse for terrorist financing and to take appropriate measures without penalizing the sector's lawful charitable activities. Moneyval, which periodically assesses Albania under the same international standard, had identified the need to strengthen capacity and awareness in this sector, which is why the training with NGO representatives was organized.
Types of NGO abuse
The training presented the typical methods by which terrorist organizations may attempt to use an NGO as a fundraising channel under a seemingly legitimate cause, as a financing bridge to conflict zones, or as an identity shield for individuals under investigation. The purpose of identifying these typologies was not to scare the sector but to equip NGOs themselves with the tools to recognize and avoid them from the outset.
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Preventive measures that every NGO should have
Although Directive No. 19/2019 and the supervisory institution have evolved over time (today the Financial Intelligence Agency, AIF), the practical principles derived from this type of training remain the same, knowing the source of funds and donors, verifying the identity of the ultimate beneficiaries of projects, maintaining regular and accessible financial documentation for inspection, and reporting any transaction or request that appears unusual for the nature of the organization's activities.
How we handle this with our clients
When we assist a nonprofit organization, we help it maintain clear financial documentation of the source of its funds and their destination so that, in the event of an audit or request from the AIF, the response is prompt and evidence-based, not improvised.
Frequently asked questions
Does FATF Recommendation 8 apply to every NGO in Albania?
Not all NGOs carry the same level of risk. The FATF calls for identifying the parts of the sector that are most exposed, based on the nature of their activities and geographic area of operation, rather than applying a one-size-fits-all approach to the entire sector.
Is DPPPP the same institution today?
Not under the same name. Its functions are now administered by the Financial Intelligence Agency (AIF). Institutional details are covered in the article linked above.
Where can I find the current FATF recommendations and Moneyval reports?
On the official websites of the FATF and Moneyval (Council of Europe), where evaluation and follow-up reports on each member country, including Albania, are periodically published.
