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24 June 2021

Workshop with public authorities, banks and NGOs on anti-money laundering and terrorist financing measures


On 16 and 17 June the workshop:  "Financing terrorism and the non-governmental sector in Bulgaria" was held on with the participation of representatives of state bodies, financial institutions and civil organizations. The seminar was organized by RUSI Europe [1] with the participation of experts from Greenacre Group[2] and in partnership with the Financial Intelligence Directorate of the State Agency for National Security and the Bulgarian Center for not-for-Profit Law.

"At the moment, the measures are sufficient, but there is a need for more communication in order to be more effective." - shared a representative of a banking institution and agreed by the other participants in the workshop.

Bulgaria is in mutual evaluation process of the compliance with the international standards in the field of anti-money laundering and terrorist financing measures set by FATF. [3] During the seminar it was stressed out that the subject of the evaluation is not only the technical implementation of the standards (a certain legal framework), but also the effect of the implementation of this framework.


What is the link between terrorist financing and NGOs

According to FATF standards, financial institutions and designated non-financial businesses and professions are obliged to apply measures against money laundering and terrorist financing (these are the so-called obliged persons).

In 2012, the FATF adopted that regulations and measures should be developed on a risk-based approach and their effect to be considered.

“Not all NPOs are high risk, and some may represent little or no risk at all.”[4]

The current Anti-Money Laundering Measures Act, adopted in 2018, includes the risk-based approach. The law treats the NGOs as a special category obliged entities in order to take into account certain characteristics of the non-profit organizations and not to allow restriction of their legitimate activity.


"10.2. To what extent, without disrupting legitimate NPO activities, has the country implemented a targeted approach, conducted outreach, and exercised oversight in dealing with NPOs that are at risk from the threat of terrorist abuse? [5] - the answer to this question shows what effect the state's actions have on the civil sector and this will be analyzed during the Bulgaria’s mutual evaluation process conducted by MONEYVAL.[6]


The perspective of public authorities, banks and NGOs

The seminar participants had the opportunity to discuss the current challenges, to think about the possible solutions and to share their perspectives and opinions on:

How to ensure that the civil society sector as a whole is not unnecessarily restricted and that appropriate and effective measures will be applied to those organizations found to be vulnerable to the risk of being used for terrorism financing.


The road goes through a sectoral risk assessment

“We need to understand the risk factors specifically for our country.” – stated a participant representing an NGO.

What do we need to do to gain a better understanding of which organizations are more vulnerable and what would be the appropriate measures to reduce this vulnerability?  This issue was a key question in the discussions between the participants.

Everyone agreed that a risk assessment of the NGO sector needs to be carried out. It will increase the understanding of both other obliged persons for the NGOs as their clients (e.g. banks) and of the organizations for themselves. Understanding what risk factors they need to watch out for and how vulnerable they are to these factors is a starting point for the establishment of a regulatory framework and the implementation of actions by the authorities which are effective and do not lead to restriction of the legitimate activities of the NGOs and shrinking the civic space.

The representatives of the FIU-SANS stated that a risk-assessment of the NGO sector is planned to be carried out and that the participation of both civil organizations and other public authorities and obliged persons who can contribute to the collection and analysis of data for the sector will be valuable. An important feedback from all the participants – NGOs, financial institutions and public authorities - was that it is crucial for everyone to have their active role, willingness to interact and collaborate in order to find the best solutions for an effective implementation of the legal framework.


[1] RUSI Europe, the European subsidiary of the Royal United Services Institute (RUSI), is a think tank working for a safer and more stable Europe. The organization holds series of workshops in various countries on questions regarding the measures against terrorism financing and its effect on civil organization. The initiative is part of CRAAFT project (Collaboration, Research & Analysis Against the Financing of Terrorism), funded by the European Union’s Internal Security Fund – Police.

[2] Greenacre Group is a leading world consulting company, focused on creating a safe, transparent and free environment for the civil society development.

[3] Work group behind Financial actions (FATF) is intergovernmental organ, which Determined International Standards with purpose Prevent Illegal Activities along financing on terrorism and Money laundering on money and Injury, that Cause on Society. like organ behind Create on Policy FATF Works behind Generate on Necessary Political will behind implementation on National Legislative and Regulatory Reform In the these Area.

[4] The International Best Practices: Combating the Abuse of Non-Profit Organisations (FATF (2015))

[5] Immediate Outcome 10, FATF Recommmendations

[6] The Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism - MONEYVAL is a permanent monitoring body of the Council of Europe entrusted with the task of assessing compliance with the principal international standards to counter money laundering and the financing of terrorism and the effectiveness of their implementation