Report looks at how to resolve conflict between compliance and crisis needs

A new report aims to find a balance between the need for speedy responses to humanitarian crises, and the risk of CSOs and other organisations unintentionally supporting illicit activity.

The Tbilisi Principles outline that humanitarian responses to crises are often unintentionally slowed or disrupted by laws designed to prevent money laundering, terrorist financing and other illegal actions.

The document’s five central principles recognise the vital role that CSOs play in responding to major crises, and argue that during such moments, governments and financial institutions ought to increase their tolerance of risks to financial integrity. They also set out the importance of planning ahead, so that all organisations involved in a crisis response are prepared to make the necessary temporary changes.

The paper says:

“Even in normal times, finding the balance is not easy. We must accept that in times of crisis that balance may shift, even if temporarily, towards accepting more risk in order to facilitate vital humanitarian action. But if this balance must shift, it is best that it shifts quickly and in a planned and deliberate way.”

The document includes recommendations for the Financial Action Task Force; the European Union (in partnership with the European Banking Authority); governments; financial institutions; donors; and CSOs.

Donors are advised to create a humanitarian preparedness plan in advance of a crisis, and to make “proportionate adjustments” to processes in the event of a crisis, as well as supporting CSOs to invest in security and human resources.

CSOs should proactively engage in anti-money laundering and combating the financing of terrorism activities in countries in which they operate. They should also set and follow high standards for financial control and other measures which create financial integrity, and work to raise awareness of this best practice.

The Tbilisi Principles were drafted following a conference in the Georgian capital earlier in the summer. Attendees included civil society organisations (CSOs) and international alliances from Europe and beyond, as well as the European Commission-funded EU Global Facility on Anti-Money Laundering and Countering the Financing of Terrorism.

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