The Financial Action Task Force (FATF) launched a project in February 2021 which studies and mitigates the unintended consequences resulting from the incorrect implementation of the FATF Standards. There are four areas of focus for this project which are: de-risking; financial exclusion; undue targeting of NPOs; and curtailment of human rights (with a focus on due process and procedural rights). The first agreed phase was a stocktake and on 27 October 2021, the FATF published its High-Level Synopsis of the Stocktake of the Unintended Consequences of the FATF Standards. The high-level synopsis summarises a longer stocktake report, which itself brings together existing knowledge from various sources as a basis for policy decisions.

During the next phase of this project, the FATF will identify and consider potential options to mitigate these unintended consequences. The results of the first phase of this project will also inform the FATF’s work on the strategic review, which aims to make the FATF more timely, targeted and effective at holding countries to account.