Published: June 2025

Venezuela has implemented new risk management rules for banking institutions which could negatively impact the right to freedom of association for non-governmental and nonprofit organizations (NPOs) in the country. 

The rules, which were published on March 31, 2025, require banks to develop and implement an elaborate set of policies and procedures to prevent money laundering, terrorism financing and financing of the proliferation of weapons of mass destruction.

An ICNL analysis has found that the rules include measures which impermissibly restrict NPOs’ association rights and contravene the Financial Action Task Force’s (FATF) international standards for the prevention of terrorism financing.

ICNL identified to two key concerns about the Rules, which are formally known as the Rules relating to risk management and supervision of money laundering, terrorism financing and financing of the proliferation of weapons of mass destruction for banking sector institutions:

• Restrictions on freedom of association — the Rules require banking institutions to supervise NPOs’ financing on vague and excessive grounds, and to conduct investigations that violate NPOs’ right to receive and use funding.
• Non-compliance with international standards for countering the financing of terrorism — the Rules require banking institutions to use a “one-size-fits-all” approach to their NPO clients, applying disproportionate measures to mitigate terrorism financingthreats and subjecting NPO activities to a supervisory regime more appropriate for entities that present a higher level of risk.

In 2023, the Caribbean Financial Action Task Force, the FATF-style regional body to which Venezuela belongs, rated the country non-compliant with FATF Recommendation 8, which aims to protect NPOs from potential abuse for terrorism financing. Venezuela’s new rules perpetuate this problem and enlist the financial sector to enforce it. 

To read our full comments, please reach out to lac@icnl.org.