ICNL helps Malawi CSOs Launch New Coalition to Monitor FATF Implementation

Published: June 2025

Over 20 civil society organizations in Malawi have established a new coalition to monitor implementation of Financial Action Task Force (FATF) measures in the country’s nonprofit sector, thanks in part to assistance from the International Center for Not-for-Profit Law (ICNL).

The CSO Coalition on FATF, which was launched in May 2025, will also coordinate advocacy, share information, engage government authorities, and work to ensure that the nonprofit sector is not adversely affected by the misapplication of FATF measures. The launch came at the conclusion of a training on FATF issues organized by the ICNL and the Centre for Human Rights and Rehabilitation (CHRR), with support from the Zambia Council of Social Development.

FATF is an intergovernmental body that sets international standards to prevent the misuse of financial systems by criminal and terrorist organizations. In some countries, however, FATF’s Recommendation 8 – which focuses on combating terrorist financing through nonprofit organizations (NPOs) – has been improperly implemented to restrict the operations of nonprofits, reducing their access to essential funding. 

This has been the case in Malawi, which was rated non-compliant with Recommendation 8 in 2019. Since then, the government has taken steps to address these deficiencies, but some concerning legal provisions still remain. The CSO Coalition on FATF will play an important role in ensuring Malawi continues its trajectory towards full compliance with FATF Recommendation 8. 

Malawi recently completed its first-ever NPO Sector Risk Assessment, a new process that FATF began requiring in 2023. The FATF risk assessment guidance requires countries to take a more focused, risk-based approach, targeting non-profits identified at risk of money laundering and terrorist financing abuse, rather than implementing broad measures that could disrupt legitimate activities. Malawi’s sector risk assessment’s findings will be operationalized in the coming year. The coalition will advocate for meaningful inclusion of CSOs in this process and seek to ensure that it reflects a nuanced understanding of the nonprofit sector.