Financial access of Human Rights Defenders (HRDs) in Exile
Pro Publico matched the European Center for Not-for-Profit Law (ECNL) with a major global law firm to deliver targeted pro bono legal research for civil society in exile, addressing how EU anti-money laundering and counter-terrorist financing (AML/CFT) rules affect access to banking services.
Across Europe, human rights defenders (individuals and organisations) operating in exile face a quiet but severe challenge. Many are denied access to basic financial services. Bank accounts are refused or suddenly closed. Transfers are delayed or blocked. The reason, if provided at all, is compliance with AML/CFT obligations.
However, these practices frequently go beyond what EU law requires. Risk-averse interpretations of AML/CFT rules have led to widespread “de-risking”. As a result, legitimate organisations, as well as individuals defending democracy and human rights are pushed out of the financial system.
This growing tension between financial regulation and fundamental freedoms is the cause at the heart of this collaboration.
Advancing fundamental freedoms: ECNL’s mission and vision
The European Center for Not-for-Profit Law (ECNL) has spent more than twenty years working to strengthen civic space in Europe and globally. Its mission is to ensure that laws and policies protect the freedoms of association, assembly, expression, and participation.
In recent years, ECNL has increasingly focused on the situation of civil society in exile. Many organisations and activists are forced to relocate due to repression, conflict, or shrinking civic space. Once in the EU, they often discover that legal residence does not guarantee practical access to financial services.
Without a bank account, organisations cannot pay staff, receive donations, or implement projects. Financial exclusion therefore becomes a powerful tool of indirect repression. Addressing this problem is essential to ensuring that EU values are upheld in practice.
When AML/CFT rules undermine financial inclusion
To better understand the scale of the problem, ECNL conducted a comprehensive survey among exiled organisations and activists globally, with over 52% organisational respondents and 27% of individual respondents reporting challenges with opening a traditional bank account.
ECNL subsequently analysed the drivers behind these encountered challenges and drafted a set of concrete recommendations, with a focus on the European Union as many respondents reported relocating to one or multiple EU countries. These proposals aim to clarify how EU financial regulation can be applied in a way that protects both financial integrity and fundamental rights, including through legal amendments and interpretative guidance under EU law.
At this stage, ECNL required specialised legal support to ensure that its proposals were feasible, legally sound, and aligned with EU financial regulation frameworks.
Trusted expertise in EU financial regulation
Through its clearing house, Pro Publico matched ECNL with a major global law firm with a strong Banking and Finance practice and deep expertise in EU financial regulation and AML/CFT frameworks.
The pro bono work was carried out by senior lawyers specialising in financial regulation. Their experience made them particularly well placed to assess the legal constraints and opportunities under EU law.
Pro Publico ensured a swift and targeted match, focusing on delivering practical and policy-relevant legal analysis that could directly support ECNL’s advocacy work.
Delivering targeted pro bono legal research
The pro bono legal team conducted a detailed legal review of ECNL’s analysis and draft recommendations. The analysis focused on:
- the scope and limits of banks’ AML/CFT obligations under EU law
- opportunities for EU-level interpretative guidance
- the feasibility of proposed legal and policy solutions
Throughout the process, the legal team worked closely with ECNL. Feedback was practical and precise, and the team proposed relevant additions to the recommendations
From legal analysis to real-world impact
The reviewed recommendations provide a robust legal foundation for ECNL’s advocacy with EU institutions, policymakers, and financial regulators.
Thanks to this support, ECNL is better equipped to argue how financial inclusion of civil society in exile can be advanced within the EU legal framework.. The work directly contributes to protecting human rights defenders and democratic actors operating in challenging environments.
As Ivana Rosenzweigova, Senior Legal Advisor at ECNL, noted: “We were really satisfied with the professional approach of Francesco and a speedy process of finding a pro bono lawyer with the right expertise. The support we received was extremely beneficial for our research. We recommend Pro Publico and will gladly use their services again in the future.”
For the pro bono provider, the matter was equally meaningful. Applying financial regulation expertise to support democracy and civic space highlights the value of strategic pro bono engagement.
The value of strategic pro bono matchmaking
This collaboration highlights the importance of effective matchmaking in pro bono work. By understanding both the legal needs of civil society and the specific expertise of law firms, Pro Publico ensures that pro bono legal research for civil society in exile delivers real impact.
Rather than generic support, this case shows how targeted legal assistance can strengthen advocacy, influence policy debates, and protect fundamental freedoms across Europe.
Are you a civil society organisation facing legal barriers? Or a law firm interested in using its expertise for the public good?
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Thanks to @IvanaRosenzweigova, @EstherMeeste, @ECNL, @FrancescoZatelli, @ProPublico
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