Protecting charities from terrorists … and counterterrorists: FATF and the global effort to prevent terrorist financing through the non-profit sector

Abstract

What role has FATF played in the global effort to counter terrorist financing through the non-profit sector? How have advocates for the sector responded and what do these developments tell us about FATF’s operations and influence? This article reflects on the emergence and evolution of FATF Recommendation 8, initially introduced as Special Recommendation VIII after the terrorist attacks in the United States on 11 September 2001. We show how the breadth of that recommendation elicited a response in the form of a "transnational advocacy network" among those within the non-profit sector. The resulting process of dialogue and the recent change in the text of the recommendation provide important lessons for scholars and practitioners concerned about FATF's accountability and authority.