NGO’s, money laundering and terrorist financing

Abstract

The development of anti-money laundering and anti-terrorist financing regulations aimed at non-profit organizations as a result of international instruments aimed at combating corruption and drug trafficking, as well as powerful countries that make up the G7 from which the Financial Action Task Force (FATF) was created, entity that in turn develops the international standards that seek to eradicate such crimes has led to the creation of regulations in El Salvador as part of the State’s commitments to implement measures aimed at eradicating practices that allow the commission of money laundering and financing of terrorism. In this sense, it is advisable to enforce some obligations so that El Salvador, in accordance with the FATF standards, can effectively comply with them, based on one of the recommendations of the international organization, such as conducting a National Risk Assessment. In addition, brief reflections are made on the implications of anti-money laundering regulations for non-profit organizations as part of the entities subject to them and that these, in turn, do not affect the human right to freedom of association.With the implementation of the new Instructions of the Financial Investigation Unit in contrast to Recommendation 8 and its FATF Interpretative Note, comments are made on the possible repercussions that the new obligations may have for organizations with low human and financial capacity to comply with the new requirements, in view of this, there is constant insistence on carrying out an effective National Risk Assessment that would allow specific regulations to be directed to NGOs with certain characteristics and not to the universe of NGOs.