Published March 2026

Across Africa, efforts to combat money laundering and terrorist financing (AML/CFT) are rapidly transforming the operating environment for nonprofit organizations. Driven by Financial Action Task Force (FATF) standards and the reputational consequences of grey listing, governments are revising laws and regulatory frameworks at speed.

This new report examines how these reforms are affecting the nonprofit sector in Burkina Faso, Cameroon, Côte d’Ivoire, the Democratic Republic of Congo, and Mali.

While technical compliance with FATF standards is improving, our findings reveal a persistent gap between security objectives and operational reality. In the absence of a genuine risk-based approach, AML/CFT measures are often constraining the civic space nonprofits need to deliver essential services, support communities, and advocate for human rights.

The report offers practical insights for policymakers, civil society, and international partners seeking to strengthen financial integrity without undermining civic participation.

Country Specific Findings

download the full report Read the report's summary

Mali: The “Post-Listing” Legacy

Status: Exited FATF Grey List (June 2025).
Key Finding: “Delisting” has not led to a return to normal. The banking sector continues to view Nonprofit organizations (NPOs) as high-risk. The new Ordonnance N°2024-011 has permanently strengthened state supervision, creating a legacy of rigor that NPOs must navigate without sufficient guidance or dialogue.

Democratic Republic of Congo (DRC): The Humanitarian Crisis

Status: On FATF Grey List (since 2022).
Key Finding: DRC presents one of the world’s most severe humanitarian crises, with 7.3 million internally displaced persons as of 2024-2025. NPOs play an indispensable role in providing assistance. But these NPOs operate within an increasingly complex regulatory environment shaped by the country’s efforts to strengthen its AML/CFT framework. A severe disconnect exists between policy reforms in Kinshasa and operational realities in Goma. NPOs report that legitimate humanitarian activities (cash transfers to beneficiaries) are at risk of being criminalized or blocked, leading to self-censorship and operational delays in a critical humanitarian context.

Burkina Faso: Administrative Barriers to Oversight

Status: Exited FATF Grey List (Oct 2025).
Key Finding: There is an emergence of a sophisticated administrative barrier to independent oversight. While the country has successfully exited the grey list through technical compliance reforms (such as the new law on AML/CFT and on Freedom of Association), these same reforms have been accompanied by restrictive administrative decrees. Specifically, the July 2025 decree requiring a “statistical visa” for data collection serves as a de facto barrier to independent research and
civil society monitoring.

Côte d’Ivoire: Pre-emptive Restriction

Status: Listed on FATF Grey List (Oct 2024).
Key Finding: The government has responded to the listing with rapid legislative action, specifically Ordonnance n° 2024-368, which designates the Ministry of Interior (DGAT) as the primary NPO supervisor for AML/CFT. Early findings indicate this centralization has increased administrative friction. Banks are awaiting clear directives and applying pre-emptive caution, while NPOs express concern that financial oversight is being politicized.

Cameroon: The Chilling Effect

Status: Listed on FATF Grey List (June 2023).
Key Finding: The AML/CFT framework, anchored by the 2014 Anti-Terrorism Law, continues to cast a long shadow over the sector. Financial institutions, under pressure from the regional regulator (BEAC), are applying blanket de-risking measures that disproportionately affect NPOs operating in politically sensitive regions. This has created a “chilling effect” where legitimate governance and human rights work is self-censored to avoid banking complications.

The analysis of the five case studies reveals a complex and nuanced picture of the impact of AML/CFT measures on civic space. While national contexts vary considerably, underlying trends emerge, showing that the application of FATF standards, far from being a simple technical issue, is profoundly influenced by the political, security, and economic realities of each country.

The most universal finding is the deficit of trust and dialogue between state authorities (including financial regulators), the banking sector, and civil society. In all the countries studied, NPOs feel they are viewed with suspicion a priori and are rarely consulted in a meaningful way during the development or implementation of AML/CFT frameworks. This structural mistrust is the fertile ground on which operational difficulties thrive

In light of these findings, it is imperative to promote an approach that reconciles financial security imperatives with the protection of civic space and the effectiveness of humanitarian action.