According to the Moneyval Fifth Round Mutual Evaluation Report on Georgia, Georgia fails to comply with Recommendation 8 on CSOs. It has been concluded that there is a serious gap with respect to core requirements on applying risk-based approach, conducting sustained outreach and applying risk-based monitoring of CSOs. Therefore, the report lays out recommendations regarding comprehensively assessing the risk of Terrorist Financing (TF) abuse of CSOs, and developing and implementing a risk-based approach to monitor the CSO sector.
According to the recommendations, the state should reach out to CSOs and the donor community about TF threats and vulnerabilities within the sector. Also, CSOs have to monitor state measures as precaution, as there is a high risk of deteriorating CSO environment if these are adopted and implemented without CSOs involvement. Active collaboration between the CSOs and the government on anti-money laundering and counter-terrorist financing measures is important to ensure the sustainability of an enabling CSO environment. CSOs shall actively communicate with the government bodies regarding all possible responsive measures and procedures that may follow from the conclusions of the report. This involves exchanging information on possible changes in legislation and policy documents that may affect wide range of CSO environment areas (e.g. freedom of association, access to funding, etc). The state needs to implement changes and preventive mechanisms initiated to make sure that Georgia achieves certain degree of compliance with Moneyval Recommendations, while preventing negative effects over CSO environment. The measures should be targeted and proportionate, in line with the risk-based approach, and respect human rights standards on association, assembly, and expression.