How do we reduce the risks faced by NGOs and charitable organizations due to financial monitoring requirements? This requires close cooperation between state and public sectors in this sphere.
This opinion was expressed by the experts of the Ukrainian Civil Society Sectoral Support Activity during the international conference “AML/CFT/FPWMD Supranational and National Systems: Challenges and Prospects”, which was organized by the State Financial Monitoring Service of Ukraine, the Organization for Security and Cooperation in Europe (OSCE) for Ukraine and the EU Anti-Corruption Initiative in Ukraine (EUACI) on April 27-28 in Lviv.
Anna Isichko, Deputy Director of the Centre for Democracy and Rule of Law, joined the discussions and presented the expert developments as part of the project “Ukrainian Civil Society Sectoral Support Activity” to the participants. Her presentations were based on the achievements of the advocacy campaign to simplify financial monitoring and banking for non-profit organizations.
Meanwhile, Mariia Poloz, CEDEM lawyer, reported on the impact of the National Risk Assessment (NRA) on the banking services for the sector. Together with Ihor Haievskyi, Oleksandr Hlushchenko, Yurii Koniushenko, Anna Lipska, Oleh Misiura, Vira Bondarenko, Denys Khokhlov, Hennadii Zelenov and Maksym Vasiuk, they talked about the NRA-2022 report and its impact on the banking services of non-profit organizations, the degree of risk assigned to public associations, charitable and religious organizations, as well as about the involvement of the sector in the 4th round of NRA in Ukraine.
The Activity experts have confirmed their intention to hold an independent assessment of the sector, as well as to participate in the sectoral risk assessment, which is the responsibility of State Financial Monitoring Service. They also joined the discussion on effective counteraction to money laundering.
After all, together with ISAR Ednannia experts, we continue to make AML legislation understandable for all participants. In particular, in April, a series of trainings was held for CSOs (in cooperation with the Independent Association of Banks of Ukraine) and banks (in partnership with the Council of Europe Office in Ukraine). It was very valuable to hear the opinions of international AML experts, in particular, the MONEYVAL Chair Elżbieta Franków-Jaśkiewicz, MPs (Olha Vasylevska-Smahliuk and Andrii Nikolaienko), leading international experts, representatives of the UN, OSCE and the EU Anti-Corruption Initiative in Ukraine (EUACI).
In total, more than 300 participants took part in the conference online and offline, including Mariia Heletii, Maksym Latsyba, Nataliia Povtar, Ihor Koblikov. This is the first time that CSO representatives have participated in such an event, and we thank our colleagues from the State Financial Monitoring Service, the National Bank of Ukraine, the Ministry of Finance of Ukraine, State Tax Service, financial intelligence, Asset Recovery and Management Agency (ARMA), the Supreme Court of Ukraine, the Ministry of Justice of Ukraine, the National Securities and Stock Market Commission (NSSMC), international experts for the opportunity to discuss those risks which arise for civil society organizations in light of the requirements of financial monitoring in Ukraine. This conference and the level of discussion confirm that mutually beneficial cooperation on strengthening the financial system of our country is real.
We would like to thank our partners from the public sector from ISAR Ednannia, UCIPR, Center for Economic Strategies, Caritas Ukraine, the Ilko Kucheriv Foundation, IZI (Institute of Legislative Ideas), AntAC, Tabletochki Charitable Foundation, the RPR Coalition, Tvoya Opora for participating in the preparation of expert studies that serve as the basis of our a strategy designed to improve the banking services for CSOs, their awareness of the risks of misuse of organizations for the purpose of money laundering, disseminate best practices of compliance with the legislation, educate banks and CSOs, create the most favorable conditions for the operation of CSOs and protection of the stability of the financial system of Ukraine.
We would like to remind you that in order to improve legislation for CSOs and mitigate the risks arising from the application of legislation in the field of anti-money laundering and prevention of terrorist financing, CEDEM is implementing a number of useful activities together with the Consortium partners as part of the Ukraine Civil Society Sectoral Support Activity. Thus, on April 19-21, CEDEM representatives, together with the colleagues from the public sector and representatives of authorities, visited Germany, where they studied the experience of combating money laundering and cooperation between the government and CSOs (see CEDEM presentation available here).
The CEDEM team also held two trainings as part of the Ukraine Civil Society Sectoral Support Activity: “Peculiarities of Civil Society Organizations’ Activities and Risk Mitigation Factors” and “Peculiarities of Financial Monitoring in the Banking Services for NGOs and Charitable Organizations”. You can view them in full by the links.
The material was prepared as part of the Project Ukraine Civil Society Sectoral Support Activity implemented by the Initiative Center to Support Social Action “Ednannia” in partnership with the Ukrainian Center for Independent Political Research (UCIPR) and Centre for Democracy and Rule of Law (CEDEM) with the sincere support of the American people through United States Agency for International Development.