On 18 March 2021, the Financial Action Task Force (FATF) announced that in February it had launched a new project to study and mitigate the unintended consequences resulting from the incorrect implementation of the FATF Standards. The project will look at four areas:

• De-risking.
• Financial exclusion.
• Suppression of non-profit organisations (NPOs) or the NPO sector as a whole through non-implementation of the FATF’s risk-based approach.
• Threats to fundamental human rights stemming from the misuse of the FATF Standards or anti-money laundering / countering the financing of terrorism assessment processes to enact, justify, or implement laws, which may violate rights such as due process or the right to a fair trial.

The FATF will conduct the project in two phases. The first phase will involve research and engagement. The second phase will involve the development of options that FATF could consider to prevent and mitigate the unintended consequences.

The FATF welcomes input to inform this project. While contributions are welcome for the duration of the project, the FATF states that they would be most relevant for phase one if submitted on or before 20 April 2021.