CAMS practice question 32 of 35

What should countries do to help prevent non-profit organizations from being abused for the financing of terrorism according to the Financial Action Task Force 40 Recommendations?

Full set: 863 questions
Answer options
A: Allow for freezing assets of non-profit organizations
B: Require all non-profit organizations to register with the country’s financial intelligence unit
C: Ensure non-profit organizations cannot be used to conceal or obscure the diversion of funds intended forlegitimate purposes to terrorists’ organizations Correct answer
D: Create laws that forbid non-profit organizations from completing cross-border transactions without firstrunning them through known terrorist data bases
Correct Answer:
C. Ensure non-profit organizations cannot be used to conceal or obscure the diversion of funds intended forlegitimate purposes to terrorists’ organizations
Explanation

The Financial Action Task Force (FATF) Recommendation 8 specifically addresses the protection of non-profit organizations (NPOs) from abuse for the financing of terrorism. A core objective of this recommendation is for countries to implement focused and proportionate measures to protect NPOs from being exploited. One of the three primary methods of abuse identified by the FATF is the "concealing or obscuring the clandestine diversion of funds intended for legitimate purposes to terrorist organisations." Therefore, ensuring NPOs cannot be used for this purpose is a direct requirement for countries under the FATF standards. This involves promoting transparency, accountability, and robust governance within the NPO sector.

Why Incorrect

A. Asset freezing is a reactive measure under FATF Recommendation 6 (Targeted Financial Sanctions) once an entity is designated, not the primary preventative framework for the entire NPO sector.
B. The FATF mandates a risk-based approach, focusing on the subset of NPOs vulnerable to abuse, not a blanket requirement for all NPOs to register with the financial intelligence unit.
D. This describes a specific, prescriptive control. The FATF recommendations are principles-based and do not mandate this exact process for all cross-border transactions, instead focusing on a broader risk-based framework.

References

1. Financial Action Task Force (FATF). (2023, October). International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation – The FATF Recommendations. FATF, Paris, France.

Page 15, Recommendation 8: "Countries should apply focused and proportionate measures, in line with the risk-based approach, to such non-profit organisations to protect them from terrorist financing abuse, including... (c) by concealing or obscuring the clandestine diversion of funds intended for legitimate purposes to terrorist organisations."

2. Financial Action Task Force (FATF). (2015, June). Best Practices: Combating the Abuse of Non-Profit Organisations (Recommendation 8). FATF, Paris, France.

Page 7, Paragraph 9: This document elaborates on the three main avenues of NPO abuse, reiterating that a key risk is the "diversion of funds intended for legitimate charitable purposes to terrorist individuals or organisations."

3. The World Bank & International Monetary Fund (IMF). (2019). FATF Methodology for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT Systems.

Page 111, Criterion 10.3: When assessing effectiveness, examiners evaluate the measures in place to "prevent the misuse of NPOs for TF purposes," which directly relates to preventing the diversion of funds as described in Recommendation 8.

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