The new regulations determining additional requirements for the registration and operation of faith-based organisations, and conditions for them to fight against the crime of money laundering, terrorist financing and proliferation of weapons of mass destruction, are now in force. The regulations of the Chief Executive Officer (CEO) of Rwanda Governance Board (RGB) of March 6, 2025 relating to additional requirements for faith-based organisations, were published in the official gazette on March 7, 2025. ALSO READ: Closure of non-compliant faith-based organisations: What are the essential requirements? As indicated in the new regulations, RGB CEO Doris Picard Uwicyeza issued the additional requirements pursuant to the law of 2018 determining the organization and functioning of faith-based organizations, and the law of January 22, 2025 on the prevention and punishment of money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction. They are also pursuant to a review of the regulations of 2019 relating to the establishment of faith-based organizations. Here eight requirements as per the new regulations: 1. Additional requirements for application for legal personality A faith-based organisation applying for legal personality must submit to RGB additional documents including a certificate issued by the District or the City of Kigali confirming that the building designated for worship activities adheres to the legal construction requirements applicable to the specified location. Also a document confirming the exclusive use of the building for worship activities; and a document confirming the conduct of all religious rituals, ceremonies and practices exclusively within the building of the organisation designated for worship activities. The requirements also include the documents of the legal representative of the organisation and his or her deputy required by law. If such documents were issued abroad, they are channeled through the Rwandan embassy located in the country of issuance and authenticated by the ministry in charge of foreign affairs in Rwanda to ensure their validity. Other preconditions are a proof of payment of a nonrefundable service fee of Rwf2 million as a requisite for the legal personality application, paid to the national treasury; a notarised declaration of exclusive representation of the legal representative and his or her deputy certifying that they do not serve as representatives of any other organisation registered in Rwanda; and an equivalence certificate or degree in theology obtained by the legal representative and his or her deputy from foreign higher learning institutions, issued by the competent authority. They also feature evidence of religious studies completion demonstrating that the legal representative and his or her deputy, whose qualifications are unrelated to theology, have completed at least 1,200 hours of religious studies from an institution accredited by the competent authority. ALSO READ: Nearly 200 non-compliant churches in Musanze shut down in fresh crackdown 2. Prerequisites for collaboration with local authorities A faith-based organisation applying for collaboration with a district or the City of Kigali submits to RGB documents including an application letter applying for collaboration; a notarised copy of the organisation’s statute; a notarised copy of the organisation’s doctrine principles; action plan aligned with development priorities of the district or the City of Kigali; and a certificate of building compliance confirming that the building designated for worship activities complies with the legal construction requirements for the location in which the organisation operates issued by competent authority. Also, a list of at least 1,000 members of the community where the organisation intends to operate, supporting the organisation with their signatures, national identification or passport, and telephone numbers, is a must. The district or the City of Kigali provides, within 90 working days, a response to the request for collaboration with a faith-based organisation. This period is calculated from the date on which all required documents were submitted and verified. The collaboration letter remains valid for a period of five years. It may be renewed following an assessment by the district or the City of Kigali, of the implementation of the action plan and budget management by the organisation over the preceding years. ALSO READ: Kagame tasks new MPs to end disorder in churches 3. Identifying illicit funding sources and ensuring financial transparency A faith-based organisation is required to identify whether the source of funding by its donor is not derived from or associated with any illegal activities. Annual financial audit of a faith-based organisation is conducted by certified professionals to ensure transparency in financial operations. The organisation must report donations exceeding thresholds specified by law on the prevention and punishment of money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction. All financial transactions of the organisation are conducted through banks or other financial institutions accredited in Rwanda. 4. Conducting impact assessments for financial crimes prevention A faith-based organisation is required to conduct an impact assessment to identify areas potentially vulnerable to extremist activities, support for terrorism, or the proliferation of weapons of mass destruction. ALSO READ: Parliament passes tighter anti money laundering bill The impact assessment includes a review of the organisation activities; donor profile; and service areas. 5. Monitoring of high-risk transactions Still, a faith-based organisation must have systems to flag and report transactions that appear unusual or high-risk including funds from anonymous or high-risk sources; and payments to or from high-risk regions. 6. Governance and oversight A faith-based organisation establishes internal controls including clear financial management policies; separation of duties; and appointment of a compliance officer responsible for monitoring money laundering, terrorist financing and financing of proliferation of weapons of mass destruction. 7. Reporting suspicious financial activities Again, a faith-based organisation submits to RGB, a report on suspicious financial activities within 24 hours of being aware of them. The suspicious activities include financing from untrusted sources, or financial transfers involving money laundering, financing terrorism or financing the proliferation of weapons of mass destruction. 8. Restrictions on cash transactions A faith-based organisation puts in place measures to minimise cash donations [physically handing over funds to recipients] by encouraging its donors to use legally recognised banks and financial institutions. This also applies to funds that may be given to individuals or small groups affiliated with the organisation. The organisation, for cash collected during events or other religious ceremonies, documents and reports cash movements exceeding specific thresholds provided in regulations on targeted financial sanctions related to terrorism, terrorist financing, and proliferation of weapons of mass destruction. Administrative faults and sanctions Meanwhile, the regulations also provide for administrative faults and corresponding sanctions. They provide that a faith-based organisation that establishes a branch without authorisation from the district or the City of Kigali commits a fault and is sanctioned by the closure of the branch and is liable to an administrative fine of Rwf5 million. In case the organisation fails to pay the fine within the specified, it is temporarily suspended until the fine is paid, plus a late penalty of 10 per cent each month of late payment. A member of a faith-based organisation who legally represents more than one organisation (acts on behalf of them in legal matters), commits a fault and is subject to the loss of the right to represent those organisations. The district of the City of Kigali is in charge of administrative sanctions, the regulations provide, indicating that the fine imposed on a faith-based organisation that committed a fault is payable to the National Treasury within one month from the date of the sanction.
