From July 14 to 17, SPACES FOR CHANGE | S4C welcomed over 250 delegates from 33 countries across Africa and beyond, to Abuja, Nigeria, for the 3rd Africa High-Level Civil Society AML/CFT Conference 2026, themed, “Implementing FATF Recommendation 8 Correctly: Practices, Lessons Learned and Opportunities for Reform.” This historic convergence provided an arena for government agencies, financial institutions, regional bodies, international watchdogs and civil society organisations to reflect, rethink and refine efforts toward combating terrorism and building resilient financial systems that effectively deny resources to terrorist financiers without imposing undue regulatory burdens that hinder legitimate non-profit organizations. Over the three days of knowledge-sharing and inclusive dialogue across four masterclasses, five plenary sessions and six parallel sessions, delegates reached consensus that countrries’ obligation to comply with international treaties should not become an excuse for enforcing stringent countermeasures that undermine legitimate humanitarian action.
Recommendation 8 of the Financial Action Task Force (FATF) was at the centre of the three-day conversations uniting governments, regulators, financial intelligence units, law enforcement agencies, regional bodies, civil society organisations, financial institutions, academia, the media, independent experts and stakeholders engaged in the anti-money laundering and countering financing of terrorism (AML/CFT) ecosystem. FATF Recommendation 8 requires countries to identify and address terrorism financing abuse involving non-profit organisations (NPOs) by applying focused, proportionate, and risk-based measures that do not disrupt legitimate charitable work. While declaring war against terrorism is a legitimate objective, the way measures are implemented remains important.
S4C’s Board Chair, Mr. Samuel Diminas, explained why the convening was crucial and timely! Africa loses more than $88 billion every year to illicit financial flows, which deprives the continent of resources that could have gone into education, healthcare and other development needs. Poorly-designed and poorly-implemented AML/CFT regulations had, in many cases, hurt genuine non-governmental organisations, leading to frozen bank accounts, financial exclusion and limited access to banking services. The goal of combating financial crimes is to strengthen the financial system without weakening the civic space that holds the system accountable. These two goals are not in conflict, but rather, reinforce each other if compliance was handled in a collaborative rather than an adversarial manner.
Joining Spaces for Change | S4C to welcome delegates to Nigeria, the Executive Chairman of the Economic and Financial Crimes Commission (EFCC), Ola Olukoyede, represented by Mr. Harry Erin, Director, Special Control Unit against Money Laundering agreed with Mr. Diminas, highlighting the growing threats posed by terrorist financiers, violent extremists, transnational organised crime and illicit financial flows. “These threats undermine peace, weaken democratic institutions, discourage investments and divert scarce resources away from development priorities”, he said. He also reaffirmed that Nigeria’s war against terrorism financing prioritizes the risk-based approach by concentrating regulatory efforts exclusively on charities assessed to be genuinely vulnerable to terrorism financing abuse, thereby fostering a more efficient and equitable regulatory environment.
Looking back at a decade of financial integrity reforms in Nigeria, S4C’s Executive Director, Victoria Ibezim-Ohaeri, reminisced on the organization’s decade-long advocacy to ensure that the war against terrorism does not constrict the operating environment for civil society operations in West Africa. During this period, S4C’s close cooperation, research, capacity-building and technical assistance to regulatory bodies, law enforcement and security agencies have recorded significant progress, culminating in stronger collaboration between regulators and civil society, the reform of the country’s anti-money laundering and anti-terrorism frameworks, and greater involvement of local experts in national terrorism financing risk assessments. More specifically, early engagements between regulators and civil society were characterised by mistrust and confrontation, but have now evolved into partnerships that resulted in local experts participating in national risk assessments and reforms that removed non-profit organisations from the list of obliged entities under national anti-money laundering laws. Ms. Ohaeri credited the leadership of the EFCC, SCUML, the Nigerian Financial Intelligence Unit (NFIU) and other oversight agencies for initiating and sustaining these reforms. Consequently, Nigeria’s experience is increasingly becoming a model for other West African countries such as Ghana, The Gambia, Togo and Burkina Faso, which are considering similar reforms.
The success story Nigeria has recorded in implementing FATF Recommendation 8 is not uniform across the continent. In his keynote, the United Nations Special Rapporteur on the promotion and protection of human rights while countering terrorism, Prof. Ben Saul, said many governments had in the past, misinterpreted FATF Recommendation 8 by placing unnecessary regulations on the entire non-profit sector. Excessive compliance requirements, poor risk assessments, and overregulation had, in many countries, disrupted humanitarian activities, restricted civil society operations, and contributed to financial exclusion through account closures and the denial of banking services. Also, some countries have adopted broad, and sometimes disproportionate, regulatory approaches, placing significant burdens on legitimate non-profit organisations, including restrictions on access to funding and banking services, excessive reporting requirements, deregistration and other forms of regulatory pressure.
Recognising the pervasiveness of these unintended consequences, FATF revised Recommendation 8 in November 2023, encouraging a focused, proportionate and risk-based approach. FATF has also clarified that countermeasures should apply only to non-profit organisations considered vulnerable to terrorist financing risks. This means that countries should first understand the risks within their NPO sectors and then develop measures that respond to those risks, rather than applying blanket restrictions across the entire sector. Taking this approach requires “stronger cooperation between governments, regulators and civil society based on meaningful participation rather than mere consultation,” Civic Advisory Hub’s Executive Director, Yona Wonjala said.
A unique feature of the 3rd Africa High-Level Civil Society AML/CFT Conference 2026 is the “conference within a conference” model allowing diverse stakeholders from national, regional and international organizations to share their disparate expertise and independently steer new conversations and topical issues arising from the implementation of FATF Recommendation 8 around the world. The session by Human Security Collective examined how humanitarian organizations across the world are leveraging trisector dialogues to navigate the difficulties they face in accessing financial services arising from the implementation of anti-money laundering and countering the financing of terrorism measures.
Bringing this conversation nearer home, the session led by Spaces for Change and Nigeria’s Multistakeholder Working Group on Charities (MSWGC) shared deep insights into the MSWGC’s financial inclusion drive for NPOs in Nigeria, highlighting how trisector dialogue platforms in Nigeria are helping financial instiutions, non-profits and law enforcement agencies move from the rules-based to the risk-based approach, thereby removing the barriers to financial inclusion.
Financial institutions were consistently named as leading the stringent enforcement of AML/CFT measures in ways that have restricted the ability of charities to access financial services. The financial institutions were also in the room to tell their own side of the story regarding how they are balancing rigid compliance with humanitarian action. The session led by the Compliance Institute of Nigeria (CIN) and International Federation of Compliance Associations shed light on the ways banks and other financial institutions are ensuring that the enforcement of AML/CFT compliance measures does not obstruct legitimate humanitarian action.
Some countries have responded to negative ratings on FATF Recommendation 8 by hastily enacting restrictive laws to improve their standing or avoid “grey-listing,” leading to burdensome, non-risk-based regulations. Negative ratings and “grey-listing” by regional assessors like the Intergovernmental Action Group against Money Laundering (GIABA) pressure countries to implement restrictive, often blanket, regulatory measures to demonstrate compliance. So, what do external assessors at the Financial Action Task Force (FATF) and FATF regional style bodies (FSRBs) like GIABA look out for when determining whether or not a country is compliant with FATF Recommendation 8? The session hosted by GIABA and Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) provided guidance to countries regarding what proportionate, targeted and risk-based approaches mean in practice. They also reaffirmed that trust between regulators and civil society is critical for the effective implementation of FATF Recommendation 8.
The pre-conference masterclasses explored how African NGOs are responding to Recommendation 8, and how charity regulators in West Africa are striking the balance between countering terrorism financing and protecting the NPO sector from terrorism financing abuse. Accordingly, civil society voices were heard loud and clear at the conference. Across panels and in dedicated sessions, African CSO networks shared how they are partnering to safeguard civic space and improve their compliance with anti-money laundering and countering the financing of terrorism (AML/CFT) standards. Several African organizations and NGO umbrella bodies such as the Centre for Human Rights and Policy Studies (CHRIPS), Kenya NPO Working Group, Muslims for Human Rights (MUHURI) | Article 19 Eastern Africa, Action Group on Free Civic Space, INGO Forum, The Association of NGOs in the Gambia (TANGO), Spaces for Change and Civic Advisory Hub, led some of these conversations.
The question of proportionality, especially the impact of blanket regulation, dominated the discussions across masterclasses and the plenary sessions. There was consensus among delegates that financial integrity and the protection of legitimate civil society activity should not be treated as competing objectives. When an entire sector is treated as inherently vulnerable, organisations that pose little or no identifiable terrorism financing risks can find themselves subjected to the same regulatory demands as organisations operating in genuinely high-risk environments. For smaller organisations in particular, the resulting compliance burden can consume resources that would otherwise go towards humanitarian work, peacebuilding, human rights protection and community development.
Blanket regulation is exacerbated by overregulation, particularly where countries implement measures that exceed what is required by FATF to combat money laundering and terrorism financing (AML/CFT). The report launched by SPACES FOR CHANGE at the conference brought these concerns to the fore. The report, “OVER-COMPLIANCE WITH FATF RECOMMENDATION 8 IN WEST AFRICA: TOWARDS DISMANTLING REGULATORY BURDENS FOR NGOs” presented very detailed evidence showing how countries panic and respond to low ratings on FATF Recommendation 8 with disproportionate regulatory reforms and blanket crackdowns.
It was clear from the conversations that FATF Recommendation 8 remains one of the most misunderstood FATF Standards. Some jurisdictions continue to attribute risk to the NPO sector by default, or wrongly equate their misconceptions of the sector with higher risk, or even mistake uncertainty for vulnerability. They also fail to engage the NPO sector, making it harder to clear misconceptions and dismantle assumptions. The conference therefore reinforced the imperative of moving from a blanket approach towards a genuinely risk-based one. Regulations should follow evidence, not assumptions, as underscored throughout the three days of discussions.
A A major highlight of the conference is the dedicated session–WOMEN IN AML/CFT AFRICA–-featuring women occupying c-suite roles in Africa’s leading AML/CFT institutions. They shared experiences of leadership, career development and the challenge of balancing demanding professional responsibilities with family life. The conversation highlighted the need for stronger gender inclusion within AML/CFT institutions and greater support for women, particularly female professionals seeking to build careers and assume leadership roles in a field that remains largely male-dominated. The regulatory compliance and AML/CFT ecosystem still need highly capable professionals. AML/CFT female leaders shared how women can anchor themselves in critical, high-utility domains that directly influence national security and economic growth through collaborations, strategic alliances and friendships while enabling shifts from siloed operations to unified networks.
The Abuja conference was more than just conversations about compliance. It was about getting the balance right; about protecting financial systems from abuse; and preventing terrorists from having access to finance through non-profit channels knowingly or unknowingly. However, these objectives should not stifle the regulatory environment for legitimate civil society organisations or the communities they serve. The 3rd Africa High-Level Civil Society AML/CFT Conference demonstrated the value of uniting diverse stakeholders under one roof to discuss and locate common grounds to these different perspectives. Implementing Recommendation 8 correctly, therefore, requires more than compliance with a global standard: It requires context, evidence, proportionality, meaningful engagement with civil society and respect for human rights. Financial integrity and civic freedom do not have to be opposing goals. That is the conversation Abuja has started, and it is one that Africa must continue!
SPACES FOR CHANGE organized the 3rd Africa High-Level Civil Society AML/CFT Conference 2026 [tagged #3AMLCFT2026] in collaboration with several local, regional and international partners, namely—Special Control Unit against Money Laundering of the Economic and Financial Crimes Commission (EFCC), Civic Advisory Hub, Human Security Collective, Fund for Global Human Rights, International Center for Non-profit Law, United Nations Office on Drugs and Crimes (UNODC), Action Group on Free Civic Space, CSO Coalition on Human Rights and Counter Terrorism and the Intergovernmental Action Group against Money Laundering in West Africa (GIABA).
