Spaces for Change | S4C and Africa Center for Democracy and Human Rights Studies (ACDHRS) co-hosted the Regulatory Compliance Clinic (RCC) in Banjul, The Gambia, on January 29–30, 2025. Supported by the Mott Foundation under the West Africa Security Advocacy Project (WASAP), the event brought together executive directors, finance and admin officers, program officers and administrators of 25 non-profit organizations (NPOs) operating in The Gambia and Sierra Leone. S4C’s Regulatory Compliance Clinics increase the capacity of NPOs in West Africa to navigate and adapt to the complex regulatory environments in their countries as well as adopt global best practices in corporate governance, financial resilience, and compliance with anti-money laundering (AML) and counter-terrorism financing (CFT) frameworks.
The RCC provided a platform for learning, dialogue, and advocacy. As with most participants across West Africa, the RCC Clinic was an eye-opening experience, being their first time of being exposed to deep insights and knowledge about terrorism financing concepts, techniques and typologies, inherent vulnerabilities in some specific charitable activities and how to mitigate those risks. Participants left with a deeper understanding of the regulatory landscape in The Gambia and Sierra Leone, the applicable regulatory frameworks and a renewed vigor to improve their regulatory compliance culture.
In a context where the blanket restrictions on NPOs imposed by a plethora of national NGO laws are the norm, how to apply the risk-based approach in a way that is proportionate and targeted dominated the discussions at the Clinic. Would the application of the risk-based approach vary from country to country? Participants shared experiences of the various sector-wide restrictions applicable in their countries that potentially disrupt the activities of legitimate NPOs. They also sought guidance on how to spearhead reforms consistent with the risk-based approach enunciated in Recommendation 8 of the Financial Action Task Force Standards.
The discussions also exposed other adverse impacts arising from the implementation of terrorism financing measures in the domestic context, especially financial exclusion. Just like regulators, banks often adopt a one-size-fits-all approach, de-risking NPOs by closing their accounts or denying them access to financial services without justifiable reasons. One participant shared a personal experience of being unable to receive funds from overseas despite having a bank account. In several instances, funds were reversed to the originating bank without explanation. This practice, they argued, undermines the work of legitimate NPOs and creates unnecessary barriers to financial inclusion. This sparked a lively discussion about the need for greater collaboration between NPOs, regulators, and financial institutions to address the challenges of de-risking. Participants also explored strategies for mitigating AML/CFT risks within the NPO sector, including implementing robust internal control measures.
One of the most striking revelations for participants was the stringent regulatory environment in Sierra Leone. NPOs in the country are required to meet several preconditions before they can operate, including having a minimum of five staff members, registering in every district where they intend to operate, maintaining an office in each of those districts, and registering with various ministries and commissions relevant to their thematic areas. Many participants expressed concern about the financial and administrative burden these requirements place on NPOs, particularly smaller organizations with limited resources.
The workshop also emphasized the importance of transparency, accountability, and ethical leadership in building trust with donors, regulators, and the communities they serve. While many participants were familiar with these principles, the workshop provided a structured framework for implementing them effectively. One discussion that sparked significant reactions was the issue of corporate self-sufficiency, especially in light of the recent withdrawal of U.S. federal aid. The discussion highlighted that achieving self-sufficiency as an NPO requires discipline and patience, which over time can strengthen the organization’s financial resilience.
As the workshop concluded, participants expressed gratitude to Spaces for Change | S4C and the Mott Foundation for organizing the RCC. They called for follow-up sessions to deepen their understanding of the topics covered and emphasized the need for sustained advocacy to address the systemic challenges facing the NPO sector, particularly in Sierra Leone. The RCC not only highlighted the importance of regulatory compliance but also underscored the vital role of NPOs in promoting development, human rights, and social justice. By fostering dialogue and collaboration, the workshop laid the foundation for a more inclusive and enabling environment for NPOs in West Africa.
In her opening remarks, Commissioner Litha Musiymi Ogana of the African Commission on Human and People’s Rights noted that the RCC holds the potential to transform the regulatory landscape for nonprofit entities in Africa. She emphasized that such initiatives should be expanded across the continent, not just limited to West Africa.
