The FATF Shadow Report: Nonprofits, Financial Access, and the U.S. Mutual Evaluation

In this special episode of AML Conversations, John Byrne is joined by Ashleigh Subramanian Montgomery of the Charity & Security Network to discuss C&SN’s newly released Shadow Report on the U.S. FATF Mutual Evaluation and what it means for nonprofits, financial institutions, and regulators. The conversation explores how U.S. government actions since the last FATF evaluation in 2016 have affected nonprofit financial access, particularly for humanitarian organizations operating in high‑risk and conflict environments. Ashleigh walks through the findings of the Shadow Report, including both positive developments—such as humanitarian carve-outs and improved risk-based language—and ongoing concerns around de-risking, executive actions, and the expanding use of counterterrorism authorities. John and Ashleigh also discuss recent Treasury risk assessments, the gap between policy and on‑the‑ground implementation, and emerging concerns about nonprofit investigations tied to domestic terrorism. The episode concludes with practical guidance for financial institutions on communication, due diligence, and balancing AML/CFT obligations with humanitarian imperatives as FATF assessors finalize the U.S. review.