Regional AML/CFT Workshop in Skopje: Multi-stakeholder Dialogue and Cooperation Key for Effective Policies and Regulations that Protect Civic Space


The Balkan Civil Society Development Network (BCSDN) and the European Center for Not-for-Profit Law (ECNL) successfully organized a regional workshop on inclusive and rights-based financial integrity. The workshop aimed to increase the knowledge and understanding of state institutions, financial institutions, and civil society organizations (CSOs) on anti-money laundering and countering the financing of terrorism (AML/CFT), as a way to ensure the development and implementation of regulations that do not restrict the legitimate work of CSOs and contribute to a safer, more secure society.

Sharing multi-stakeholder perspectives, challenges, and opportunities for cooperation from around the region, and learning from each other, was the main aim of the event. The sessions were moderated by experts and included representatives from FIUs, banks, and CSOs. The discussions focused on the characteristics and functioning of the CSOs sector, translating AML/CFT rules and regulations into guidance for financial institutions, the approach to obliged reporting entities and beneficial ownership when dealing with CSOs, implementation of national and sectoral risk assessments, and multi-sector dialogue as a way to reduce the knowledge gap between stakeholders.

The workshop showed the importance of joint conversations across sectors as a way to increase the understanding of the different perspectives of all stakeholders affected by the AML/CFT regulations. It confirmed that it is imperative for all discussions and processes around those to be genuinely participatory and inclusive, for ensuring more appropriate and effective policies and regulations. Sectoral risk assessments, which aim to increase the understanding of the risks of terrorism financing to the sector and to assess how effectively CSOs are mitigating these risks, have shown to be incomparably more valuable and representative when done in partnership with CSOs. These have also shown the ineffectiveness of the approach that targets the whole sector as being at high risk for ML/FT abuse, as a real risk assessment of the sector ensures the implementation of a risk-based approach and proportional measures to protect those CSOs identified as being vulnerable, which are only a small part of the sector itself. Overregulation as a way to strengthen the supervision or control over the sector in fact often leads to impeding CSO legitimate activities. On the other hand, self-regulation aimed to strengthen the CSO internal governance enables CSOs to increase their understanding and compliance with the legal obligations, the potential risks of money laundering and terrorism financing, and to adopt measures to mitigate those. This approach is key for making the sector more secure and resistant to abuse, while ensuring the respect of freedom of association and expression, and allowing CSOs to continue unhindered in pursuing their mission and legitimate activities.

The gathering also offered an opportunity for CSOs throughout the region to discuss the draft FATF Best Practice Paper revision, by sharing their direct experience and knowledge to feed inputs back to FATF, as well as to formulate a joint position towards the Regional TF Risk Assessment by Council of Europe. BCSDN will continue facilitating the regional exchange and lessons learned, supporting stronger regional cooperation and joint advocacy efforts in the region, and, through the support of ECNL, ensure increased contribution and involvement of WBT CSOs in international and global AML/CFT initiatives.

The workshop concluded on a very positive note shared by all participants, as each country delegation discussed and agreed on the next steps for continuing the multi-stakeholder dialogue and cooperation on national level, while state officials expressed their commitments to improve the legal framework and deal with problematic AML/CFT regulations and practices in each of the countries.


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