Scope of Article 118 CRR - World Food Programme

Can the  Risk Weight of 0%  according to Article 118 CRR be applied on  the World Food Programme (“WFP”)?   According to Article 118(f) CRR exposures to an international financial institution established by two or more Member States which has the purpose to mobilise funding and provide financial assistance to the benefit of its members that are experiencing or threatened by severe financing problems, shall be assigned a risk weight of 0%. Can WFP be classified as an international financial institution in the meaning of Article 118 (f) CRR ?

We think, that there may be reasons to qualify the WPF as such an international financial institution ("IFI") for the following reasons:   The WFP is a part of the United Nations Sustainable Development Group (“UNSDG”).  The UNSDG focuses specifically on social progress, better living standards and human rights. All 27 European Union (“EU”) countries are members of the UN.  In 2021 the EU contributed approx $500m in donations to the WFP.  This makes the EU the 3rd highest contributor, behind the USA and UK. The WFP is governed by an Executive Board (the “Board”) which consists of representatives from 36 UN member states.  The Board provides inter-governmental support, direction and supervision of all WFP's activities.  Given its material donations, EU representatives are given the formal status of “permanent participants and observers” in the workings of the Board. The EU representatives are targeted to help to oversee and govern the WFP in terms of direction and strategic decision making. The WFP is “The world’s largest humanitarian organisation, saving lives in emergencies and using food assistance to build a pathway to peace, stability and prosperity for people recovering from conflict, disasters and the impact of climate change”.    This objective not only includes the provision of shelter, food and water, but also direct financial assistance paid to individuals.   Whilst no EEA country has as yet required specific support from the WFP, Turkey has.  Whilst Turkey is not a direct EEA member state, it was formally accepted into the European Economic Community (“EEC”) in 1999.  In 2022 Turkey continues to obtain WFP support in regard to the 4m refugees crossing its borders in the last 10 years, primarily from Syria and Afghanistan.  The WFP describes its actions in Turkey as follows:   “In addition to helping refugees through cash transfers that also boost local businesses, WFP is helping the country’s economy by buying the bulk of food commodities for the Syrian Regional Emergency Operation from Turkey”.  Furthermore the WFP has many characteristics, hallmarks and purposes of an IFI.  We conclude that the recipients of the cash funding and financial support provided by the WFP (and therefore provided by direct EU funds), would very much ostensibly view the WFP as an IFI, not just the providers of food and water.     For these reasons we think that the WFP should be classified as an IFI in the meaning of Article 118(f) CRR and as eligible for a preferential risk weight of 0%.       Clarification of this question is important in order to determine the correct risk weight for exposures towards the WFP and - with reference to Article 400(1)(b) CRR- to get clarity on the correct calculation of the Legal Lending Limit towards WFP.