This study seeks to understand the phenomenon of de-risking as it stems from global anti-money laundering (AML) and countering the financing of terrorism (CFT) rules, examining these in relation to decisions made by governments, regulators and financial institutions leading to the de-risking of NPOs. The drivers behind both global and national decision-making are analyzed and placed in a political, regulatory and security context, taking into account the normalizing of the ‘securitization’ discourse post ‘9/11’ and the internalization of this discourse by regulatory and other authorities leading to risk management and avoidance. Unpicking the mechanisms of governance and accountability inherent in the decision-making process enables a greater comprehension of this vexed issue, including magnifying the ‘unintended con-sequences’ of de-risking: the fact that it is undermining other international policy goals and concerns, such as economic development, financial inclusion, human rights protection and the creation of an ‘enabling environment for civil society’.