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Qatar: UN experts call for reform of the anti-money laundering and terrorist financing law 

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News briefing

Translated and Edited by: Committee for Justice

Geneva: April 11, 2022

UN experts made several observations regarding Law No. 20 of 2019, regarding the issuance of the Anti-Money Laundering and Terrorist Financing Law in Qatar, which may have a disproportionate impact on the ability of civil society actors and groups to work in the country.

In a memorandum sent to the Qatari government on February 8, 2022, the experts expressed concern in particular that the legislation could lead to a violation of basic human rights, including the right to freedom of association, freedom of expression, and privacy.

Notes on the law:

The experts made some observations about the articles of the law, including Article 40 of the law that prohibits non-profit organizations from operating in Qatar “without prior authorization or registration from the regulatory authorities,” and states that “when examining applications for licensing, registration or renewal, the regulatory authorities must verify the identities of the shareholders of the requesting entity and the principal management as well as the beneficial owners.”

The experts noted that current NPO registration requirements unduly restrict protected rights and freedoms, regardless of objective criteria of necessity, proportionality and non-discrimination under international law, and called on the Qatari government to ensure that licensing and registration requirements for NPOs do not impede their legitimate activities, including the exercise of the rights to freedom of association and the associated freedoms guaranteed under the International Covenant.

The experts also noted that Article 40 does not include a mechanism to challenge the rejection of applications for registration. In this regard, the experts reiterated the conclusion of the Special Rapporteur on the rights to freedom of peaceful assembly and of association, according to which “associations whose applications have been rejected may appeal the decision before a neutral and independent court.”

The experts also made observations about Article 41 of the law, which states that “the confidentiality provisions stipulated in the laws do not prevent regulatory authorities from accessing any information held by bodies under their control when necessary for the performance of their duties. Access to such information shall not be conditional on obtaining prior authorization from a judicial authority,” expressing concern that this provision would override other legal safeguards of confidentiality that might impinge on affected individuals’ rights to privacy, as well as a lack of judicial oversight, to oversee regulators’ power to monitor individuals and non-profit organizations.

Likewise, Articles 50 and 53 of the law give the Public Prosecution the authority to use special investigative techniques – secret investigations, audio-visual surveillance, access to information systems, communication interception and controlled delivery.

Experts have warned that such broad powers of access to personal information may lack adequate procedural and judicial safeguards, raising serious concerns about the required privacy protections.

UN demands from the Qatari government:

The experts called on the Qatari government to provide information on the procedural guarantees it has implemented to ensure that regulators’ powers are exercised to monitor and access the records of non-profit organizations in accordance with Law No. 20, in accordance with the principles of legality, necessity and proportionality.

The experts also called on Qatar to explain the procedures available to individuals, including human rights defenders and non-profit organizations, to file a complaint regarding the enforcement actions taken by the Civil Aviation Authority and the Public Prosecution, and what remedial measures are available, including measures to redress financial and reputational damage, as well as violations of data privacy rights.

The experts also requested the Qatari government to submit the latest national risk assessment and any additional information related to its findings and recommendations.

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