NGOs and money laundering: Adapting EU rules to engage NGOs better

Money laundering (ML) is a major global concern. The minimum identifiable direct costs of organised crime in the European Union (EU) are estimated at around €166 billion a year. Europol, the EU's law enforcement agency and Eurojust, the EU's Judicial Cooperation Unit, estimate the minimum costs of fighting organised crime at EU level amount to €210 million a year. To efficiently tackle ML the EU has stepped up cooperation with civil society, including non-governmental organisations (NGOs). NGOs are engaged as collectors of relevant information on illicit activities, and in developing standards and implementing anti-ML rules. At the same time, however, NGOs are considered 'subjects at risk' in the ML framework, either as fronts for terrorist organisations that raise and transfer funds, or as legitimate enterprises that indirectly support the aims of terrorist organisations. This double-sided position for NGOs may impact on the efficacy of the measures currently in place at EU and international level to certify their transparency and accountability. NGOs, in turn, see such attempts to regulate their activities as a threat to their independence, and thus occasionally resist them. .