Weaponisation of the FATF Standards: A Guide for Global Civil Society

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This guide endeavours to convert anecdotal evidence of abuses and misuses of the FATF system into an impartial body of research that can support existing advocacy and policymaking efforts.

The standards and processes of the Financial Action Task Force (FATF) are intended to uphold transparency and integrity within the global financial system, which in turn should curb the laundering of the proceeds of crime, stem corruption and protect the financial system from terrorist financing abuse. Yet, as with other global policy instruments, the FATF standards have been weaponised by authorities worldwide as part of holistic campaigns to crack down on targets who threaten their interests, most often civil society actors such as watchdog organisations, journalists, opposition figures and other critics who threaten regime interests or stability.

Focusing solely on laws and powers related to the FATF’s domain of anti-money laundering and counterterrorist financing (AML/CTF), and without attempting to compare this with misuse of other laws and policy areas, this guide outlines the distinct attributes of AML/CTF measures that expose them to abuse – attributes that interact with factors outside the FATF’s control to yield detrimental effects for civil society. It highlights the identities and behaviours of the actors and organisations most susceptible to targeting and indicates where and when abuses are most likely to occur. Five major typologies of abuse are identified:

  1. Intelligence fishing and scraping.
  2. Strategic bank account freezing.
  3. Harassment and prosecution of organisations.
  4. Politically motivated (pre-trial) detention.
  5. Lawfare for transnational repression.

The guide also outlines the unique impacts of such abuses on their targets, and offers civil society both tested and untested response options.

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Stephen Reimer

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