Counter-Terrorism Financing Measures in Tunisia: Impact on Non-Profit Organizations

Introduction

The Counter-Terrorism Commission (CTC) of the Tunisian government has assumed supervision over civil society organizations (CSOs), placing them under intense scrutiny for terrorism financing and money laundering. This report presents preliminary findings on the impact of counter-terrorism financing (CTF) measures on non-profit organizations (NPOs) in Tunisia, specifically their access to financial services.

Methodology

This study has reviewed laws, regulations, media coverage, and scientific literature related to the subject. A total of 20 interviews were conducted with various stakeholders, including banks (public bank, private Tunisian bank, branch of an international bank), the post office, and possibly other organizations involved in financial services. Although not all focus groups were conducted as initially planned, some may have been held to gather more information from specific stakeholders or groups.

Key Findings

Changes in the Tunisian Government’s Approach

• The CTC has assumed supervision over CSOs, placing them under intense scrutiny for terrorism financing and money laundering.
• CSOs are now considered high-risk, unlike in 2019 when they were deemed low-risk by the Counter-Terrorism Financing Authority of Tunisia (CTAF).

Shift in Risk Assessment

• The risk assessment of CSOs has changed significantly, with many organizations now being viewed as high-risk entities.

Increased Legal Proceedings against CSOs

• Many CSOs have been subject to legal proceedings based on suspicions of involvement in terrorism financing and money laundering.
• These legal proceedings have created uncertainty and fear among NPOs, making it challenging for them to operate effectively.

President’s Involvement

• The President of the Republic, Kaïs Saïed, has become directly involved in addressing financial irregularities within institutions.

Recommendations

Based on the preliminary findings, some potential recommendations for ICNL, its partners, and public institutions involved could be:

1. Collaborate with Financial Institutions: Work closely with banks and other financial institutions to establish clear guidelines and procedures for NPOs’ access to financial services.
2. Provide Training and Resources: Offer training and resources to help NPOs understand and comply with CTF regulations, as well as provide guidance on risk management and due diligence practices.
3. Advocate for Policy Changes: Advocate for policy changes that address the concerns of NPOs, such as clarifying their risk status or establishing more effective procedures for reporting suspicious transactions.
4. Foster Stakeholder Engagement: Foster dialogue between financial institutions, government bodies, and NPOs to ensure a better understanding of each other’s needs and challenges.

By working together, these stakeholders can help create an environment that balances the need to prevent terrorism financing with the need for NPOs to access essential services.