Spaces for Change | S4C organized the fifth edition of the NGO Regulatory Compliance Clinic for non-governmental organizations (NGOs) operating in North-West Nigeria on August 10, 2022. The clinic, organized under the auspices of the West Africa Civic Space Resource Hub initiative, brought together thirty-four (34) organizations working across different thematic areas in Kano, Kaduna, Katsina and Zamfara States. Subject matter experts from the Economic Financial Crimes Commission (EFCC), Corporate Affairs Commission (CAC), S4C, and independent consultants delivered presentations designed to help NGOs understand and increase their compliance with the plethora of regulatory requirements applicable to them. Enhanced compliance with regulations forms part of a broader strategy to push back on regulatory restrictions that could potentially limit civil society.
Participants learned about laws applicable to NGOs and their reporting and filing obligations to regulatory bodies like the CAC, Special Control Unit against Money Laundering (SCUML), and Federal Inland Revenue Service (FIRS). They also learned about anti-money laundering/countering the financing of terrorism (AML/CFT) checklists and controls every workplace should have in place. Organizations in the North-West operate in a climate of civil unrest and insecurity, such as the activities of bandits hiding in the thick forests dotting the region. States like Kaduna, Katsina, Kano, and Zamfara have a continuous stream of incidents, usually involving religious, political, and ethnic violence. Not only that, humanitarian entities rely largely on donations from the public and private sources. As a result of the combination of these factors, NGOs operating in the region may be at risk of terrorism financing (TF). The checklists provided templates organizations could use to minimize their TF risks.
National AML/CFT regimes draw inspiration from the standards set by the Financial Action Task Force’s (FATF’s) Recommendations. FATF’s Recommendation 8 (R8) applies explicitly to non-profit organizations (NPOs). Through dedicated presentations and exercises, participants learned more about FATF and why and how these international regimes apply to NPOs.
The NGO Regulatory Compliance Clinic consists of 6 independent courses detailing the litany of applicable legal regimes, the roles of regulators and regulated entities, timely reporting mandates, and the opportunities for reform. The pre-clinic evaluations indicated that many NGOs in the region were neither aware of AML/CFT regimes nor the new regulatory requirements applicable to non-profits espoused in the Companies and Allied Matters Act (CAMA) 2020 and the freshly-minted Money Laundering (Prohibition) Act (2022), and the Terrorism (Prevention) Act 2022. By participating in the Clinic, these trends are now changing. Take a look at some of the feedback from the Clinic:
The CSR-Hub is supported by Ford Foundation and aims to equip civil society actors across West Africa with the relevant tools to push back against the closing civic space in the sub-region.