Mauritius's Second NPO Terrorist Financing Risk Assessment: Evidence-Based Differentiation Over Blanket Controls

Mauritius has published its Second Terrorist Financing Risk Assessment of Non-Profit Organisations (February 2026), issued by the Ministry of Financial Services and Economic Planning.

• The full public report is available here: https://bom.mu/sites/default/files/second_terrorist_financing_risk_assessment_of_npos_-_public_report.pdf
• Bank of Mauritius confirmation and context appear here: https://www.bom.mu/financial-stability/amlcft

The assessment concludes

• That the overall risk of terrorist financing (TF) abuse of the Mauritian NPO sector is Low.
• Approximately 98% of NPOs are assessed as having little or no exposure.
• Residual risk for the dominant legal forms — associations, charitable foundations, companies limited by guarantee and waqfs (collectively ~99.2% of the sector) — is rated Very Low.
• Certain residual risks sit higher (Low or Low-Medium): online crowdfunding, control of NPOs by individuals from high-risk jurisdictions, and charitable trusts.
• These findings align closely with the summary circulating on professional networks. They also represent a clear downward movement from the 2020 assessment, which rated inherent TF risk as Low-Medium.

What the assessment actually shows

The methodology is multi-agency and multi-source: official data from regulators and law-enforcement bodies, 988 NPO survey responses, interviews, review of the 2025 National Risk Assessment (which rates national TF risk Medium-Low), and comparative analysis with peer jurisdictions.

• There are no known convictions, prosecutions or investigations that have uncovered TF abuse of Mauritian NPOs since the previous assessment.
• Suspicious transaction reports involving NPOs remain very low in absolute terms.

Four areas of elevated (but still modest) exposure are flagged:

• Fundraising for humanitarian causes in high-risk jurisdictions (risk of diversion or support to foreign terrorist fighters).
• Links with high-risk jurisdictions, including the possibility of foreign nationals sympathetic to extremist causes controlling NPOs.
• Use of online crowdfunding or virtual assets to raise or move funds.
• Oversight and monitoring of charitable trusts (the smallest category, ~0.81% of FATF NPOs).

Mitigating measures for the bulk of the sector are judged generally effective.

• Specific deficiencies are noted around charitable trusts and the incomplete regulatory treatment of online crowdfunding platforms.
• Residual ratings after mitigation remain Low or Low-Medium in those pockets.

Why this matters beyond Mauritius

• FATF Recommendation 8 and Immediate Outcome 10 require countries to identify the subset of NPOs that fall within the FATF definition, assess the nature of TF risks to them, and apply focused, proportionate, risk-based measures that do not unduly disrupt legitimate activity.
• Mauritius's report is a concrete demonstration of that sequence. It rejects the blunt approach of treating every association, foundation or trust as equally risky.
• Instead it concentrates attention on the small minority of activities, structures and relationships that present higher exposure.
• This is the correct direction of travel.
• Over-broad or poorly calibrated controls on NPOs have well-documented unintended consequences: reduced access to banking, higher compliance costs that fall disproportionately on smaller organisations, and a chilling effect on legitimate cross-border humanitarian and development work. The Mauritian assessment explicitly notes the absence of widespread de-risking problems and treats preservation of NPO access to financial services as a relevant consideration.
• At the same time, the residual ratings should not be read as a clean bill of health. Absence of detected cases is not proof of zero risk; it is evidence that, on current intelligence and supervisory data, abuse is rare.
• Emerging channels — crowdfunding platforms and virtual assets — are still evolving faster than many supervisory frameworks.
• Charitable trusts, by their private nature, are inherently harder to monitor than registered associations. The report itself flags the need for continued vigilance and further improvements in those areas.

Practical implications

• For Mauritian authorities and supervisors, the assessment provides a clear prioritisation:
• Maintain effective registration,
• Outreach and monitoring for the low-risk majority
• While tightening oversight of the higher-exposure pockets (especially charitable trusts and newer fundraising channels).
• For financial institutions,
• It supplies an evidence-based rationale for differentiated due diligence rather than blanket enhanced measures on every NPO client.
• For the NPO sector itself,
• It is a reminder that transparency, good governance and awareness of high-risk corridors remain the first line of defence.
• More broadly,
• The exercise is a useful benchmark for other jurisdictions that are still wrestling with the practical meaning of "risk-based" under Recommendation 8.
• Stop the default high-risk
• Many still default to treating the entire non-profit sector as high-risk by association.
• Mauritius's data-driven differentiation shows a more rigorous — and ultimately more sustainable — path.
• The full report rewards careful reading.
• The residual-risk table and the discussion of unintended consequences are particularly worth examining.
• As with any national risk assessment, the findings are only as good as the underlying data and the willingness of authorities to keep the assessment under review as threat landscapes shift.
• On the evidence presented, Mauritius has moved the needle in the right direction.

Sources  

Primary official sources: https://bom.mu/sites/default/files/second_terrorist_financing_risk_assessment_of_npos_-_public_report.pdf https://www.bom.mu/financial-stability/amlcft

Secondary summary: https://www.comsuregroup.com/news/mauritius-unveils-findings-of-second-terrorist-financing-risk-assessment-of-npos/