CSOs Raise Concerns to Council of Europe on AML/CFT Report


We, the CSOs united in a front, raise our concerns directly with the Council of Europe regarding its recent report on the regional terrorism financing risk assessment of the not-for-profit (NPO) sector in the Western Balkans and Türkiye. We appreciate your efforts to address terrorism financing risks in our region, but we express reservations about certain conclusions and recommendations put forth in the report. We call upon our fellow civil society organizations and institutions across Europe to support us and join us in advocating for a more balanced and nuanced approach in addressing these concerns.

The Concerns We Raise:

We appreciate your efforts to assess and mitigate the risks of terrorism financing in our region. However, we express reservations about some of the conclusions and recommendations put forth in the report. We want to highlight the contextual differences among the selected jurisdictions and the varying weights assigned to the analysis of risk, which raise questions about the relevance and validity of the report for our entire region. Additionally, the report creates confusion regarding the mechanisms for addressing regional risks at a national and regional level, failing to provide clear guidance for effective implementation.

Implications for the NPO Sector:

One of our most pressing concerns is the framing and presentation of the report’s findings, which we deem damaging to our NPO sector as a whole. We find the blanket classification of religious/ethnic/cultural organizations or humanitarian/charitable/aid-giving NPOs as high risk without reference to mitigating measures dangerous. Such a generalized approach not only stigmatizes certain CSOs but may also provide a pretext for governments to introduce burdensome regulatory measures and suppress our sector, hindering legitimate charitable activities and diminishing the operating environment for civil society.

Lack of Clarity and Consultation:

We acknowledge the details provided in explaining the methodology used in the report. However, we want to highlight the lack of clarity on important issues, including how ‘high risk’ is determined and the selection process for the ten risk factors identified. We express serious concerns over the list of risk factors presented, as it scrutinizes routine NPO activities and characteristics that are integral to our sector’s mission and the public good. Moreover, we question the claim of sufficient data collection due to the low response rate from government institutions and NPOs, which weakens the reliability of the report’s findings and underscores the need for better consultation and engagement with stakeholders.

View the full letter here.

List of organizations:

  1. Balkan Civil Society Development Network
  2. Center for Development of NGOs, Montenegro
  3. Center for Promotion of Civil Society, Bosnia and Herzegovina
  4. Civic Initiatives, Serbia
  5. CIVIKOS, Kosovo
  6. European Center for Not-for-Profit Law
  7. Human Security Collective
  8. Konekt, North Macedonia
  9. Kosovar Civil Society Foundation, Kosovo
  10. Partners Albania for Change and Development, Albania
  11. TUSEV Foundation, Turkey

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