The government announced that it would conduct a risk assessment of non-commercial organisations’ (NCO) involvement in money laundering and terrorist financing activities. The announcement was made at the training held by the Moscow-based International Training and Methodology Centre for Financial Monitoring, where representatives of governmental agencies, financial monitoring bodies, member states of the Council of Heads of Financial Intelligence Units of the CIS Member States (Armenia, Belarus, Kazakhstan, Kyrgyzstan, Russia, Tajikistan, Uzbekistan ), and NCO representatives took part.
Importantly, the new risk assessment in Belarus will be conducted when Russia and the Commonwealth of Independent States (CIS) consider similar strategies. The subsequent report will therefore presumably not be included in the regular cycle of anti-money laundering and countering the financing of terrorism (AML/CFT) risk assessment in accordance with the FATF methodology.
Government’s rationale for launching new assessment of the NCO sector
According to the State Control Committee, the main objective of the new assessment of the NCO sector is to identify NCO forms with low, medium and high risk of involvement in money laundering and terrorism financing activities. Based on this, the state will focus its control on forms, which are identified as high or medium risk. The assessment will allow the state to determine further regulations on the NCO sector and prevent involvement of these organisations in financing terrorism and other unlawful activities. As reported, the risk assessment will be conducted with the participation of governmental agencies and representatives of NCOs, and will include trainings.
Viachaslau Reut, the director of the Financial Monitoring Department of Belarus provided further explanation why this new assessment is needed. According to him, the Control Committee of the Republic of Belarus would study CIS member states’ experience in the field of terrorist financing through NCOs. In his opinion “Belarus has already had certain negative experience in 2020, when NCOs got involved in unlawful activities. New approaches should be developed to exclude the possibility that such events may repeat. The most important thing is to prepare the population that our NCO should perform these very functions which they were established for. This problem is inherent in all countries of the world”. When journalists asked whether the government seeks to establish a separate controlling body to monitor NCOs, he explained that such body is difficult to establish in Belarus due to the specifics and diversity of NCOs: "It cannot be said that unlawful activities risks are the same in all areas. We should shortly conduct a national risk assessment in this field and develop solutions that will allow optimising control functions, and on the other hand, continuing the functioning of normally operating organisations”.
CIS countries to consolidate approaches on AML/CFT issues and establish new body
According to Olga Tissen, the head of the legal department of the Russian Federal Financial Monitoring Service: "Belarus and Russia have similar ways of countering the use of NCOs for engagement in extremism and terrorism. At the same time, we are now conducting a number of joint activities to build up a common line to combat NCOs’ involvement in unlawful activities”.
Simultaneously, CIS structures already work on mutual approaches in the AML/CFT field. On September 14, 2022, an expert group met at the CIS headquarters in Minsk to agree on the draft Agreement on the Establishment of the International Center for Assessing the Risks of Legalization (Laundering) of Proceeds from Crime and Financing of Terrorism. Representatives of Armenia, Belarus, Kazakhstan, Kyrgyzstan, Russia, Tajikistan, Uzbekistan, the Secretariat of the Council of Heads of Financial Intelligence Units of the CIS Member States, as well as employees of the CIS Executive Committee participated in the meeting to work on the draft agreement based on comments from CIS member states. After additional consultations, the next regular expert group meeting is to be held in November 2022.
Worrisome decision to implement new assessment, considering that:
The FATF methodology already showed no risk in the nonprofit sector in 2018.
In 2018, Belarus already conducted a national AML/CFT risk assessment in accordance with the FATF methodology. The assessment showed that Belarusian NCOs in general were not involved in financing of terrorism and money laundering activities. In particular, the “Summary of National Risk Assessment of Legalization (Laundering) of Proceeds from Crime and Financing of Terrorist Activities” published by the Ministry of Justice says – “In the Republic of Belarus, no activities of international terrorist organisations, their cells and members have been detected. No facts of stay on the territory of the Republic of Belarus of individuals and organisations included in the UN sanction list, location of their property, as well as other assets belonging to them have been identified. No organisations have been recognised as terrorist by the decisions of courts of the Republic of Belarus. […] There are no facts of using NCOs for financing of terrorist activities in the Republic of Belarus”. In November 2019, the Eurasian Group on Combating Money Laundering and Financing of Terrorism approved the Executive Summary and Mutual Evaluation Report of the Republic of Belarus.
Civil society has reported that authorities are abusing AML/CFT measures to crack down on their operations.
Since July 2021, more than 650 CSOs have been involuntarily dissolved in Belarus. Accusations of violating the technical rules of publishing AML/CFT reports were among the grounds for liquidating numerous leading and long-established CSOs. However, the grounds of liquidation were not in connection with CSOs violating the AML/CFT norms in their essence.
To learn more, read our 2021 Belarus country report.