The Wolfsberg Group, based in Switzerland, has provided comments on the draft amendments to the Financial Action Task Force (FATF) R.8/INR and the Best Practice Paper (BPP) to Combat the Abuse of Not-Profit Organizations (NPOs). They support the revisions to clarify the implementation of a risk-based approach and address the negative impact of preventive measures on legitimate NPO activities. The Group believes that NPOs should adopt a risk-based approach to identify and assess their own risks, and that national authorities should enforce this requirement. They also suggest amendments to enhance NPOs’ risk awareness and control frameworks. Additionally, they emphasize the importance of NPOs being able to explain their activities and risk assessment process to financial institutions. The Group provides further suggestions for qualification of the functional definition of NPOs, expansion of the reference to financial transactions, inclusion of Virtual Asset Service Providers (VASPs), and affirmation of the obligation to establish the legitimacy of funds. They also propose the inclusion of financial institutions in certain paragraphs.