Counter-terrorism Measures & Humanitarian Risk Management in Paris

Programme Overview

Humanitarian organisations often work in places where armed groups are designated under national or international counter-terrorism laws and sanctions. Those measures exist for legitimate security reasons, but they also create real risks for principled aid: funding clauses that are hard to apply, banks that delay or refuse transfers, partner and beneficiary screening demands, and legal uncertainty for staff who must negotiate access.

Independent research has documented these effects for more than a decade. A 2013 study published with the Norwegian Refugee Council (NRC) and OCHA found that counter-terrorism measures were restricting funding, stalling projects and encouraging self-censorship, with case studies in Somalia and the Occupied Palestinian Territory. NRC’s later work has shown that such measures can limit the ability to deliver aid according to need alone.

The rules have since changed in important ways. UN Security Council resolution 2664, adopted on 9 December 2022, created a humanitarian carve-out from UN asset freezes, and resolution 2761 of December 2024 extended it to the ISIL and Al-Qaida regime without an end date. The EU brought the carve-out into its own sanctions law in March 2023, and the Financial Action Task Force revised Recommendation 8 on non-profit organisations in November 2023 to require focused, proportionate and risk-based measures.

This five-day programme in Paris helps humanitarian managers understand these frameworks and build internal risk management systems that protect both the organisation and its principles. It is about compliance, due diligence and staff security for aid organisations, not about security operations.

Paris is a natural setting: it hosts the FATF secretariat at the OECD and many French humanitarian NGOs, and French courts have recently ruled on beneficiary screening demands.

The Programme Strengthens Institutional Capability

• Understanding UN, EU and national counter-terrorism and sanctions frameworks
• Applying humanitarian carve-outs and exemptions correctly
• Interpreting counter-terrorism clauses in donor agreements
• Risk assessment of programmes in high-risk areas
• Enterprise risk management linked to sanctions and counter-terrorism
• Proportionate partner due diligence
• Positions on beneficiary screening consistent with humanitarian principles
• Anti-diversion controls in procurement, cash and distribution
• Financial access and relations with banks
• Documentation and audit trails for compliance
• Codes of conduct and internal counter-terrorism policies
• Staff security and duty of care in high-threat settings
• Legal awareness for staff negotiating access
• Incident reporting and escalation
• Donor dialogue on risk sharing
• Board and senior management oversight of risk
• Monitoring and review of risk controls

The programme draws on published guidance from the UN, the EU, FATF, NRC, ICRC and other humanitarian bodies, and keeps all discussion neutral and focused on lawful, principled practice.

The Growing Importance of Counter-terrorism Risk Management for Humanitarians

Terrorism remains a serious threat in many places where humanitarians work. The Global Terrorism Index 2025 recorded 7,555 terrorism deaths in 2024, with the Sahel accounting for 51% of them, and listed Burkina Faso, Pakistan, Syria, Mali and Niger as the most affected countries. The 2026 edition reports a further fall in deaths in 2025, but the Sahel still accounts for more than half of the global total. Humanitarian needs are often greatest in exactly these regions.

At the same time, aid workers face record levels of violence. According to the Aid Worker Security Database, as published by OCHA, 383 aid workers were killed in 2024, up from 293 in 2023. That combination, high needs, insecurity and dense legal rules, makes risk management a core management task rather than a back-office function.

The legal ground is also shifting in favour of principled action, but only for organisations that can show sound controls. The UN and EU carve-outs, and FATF’s revised standard, all assume that humanitarian organisations apply credible due diligence and can explain it to donors, banks and regulators.

Organisations increasingly require professionals capable of:

• Reading sanctions lists and understanding what an asset freeze covers
• Explaining the scope and limits of humanitarian carve-outs
• Negotiating workable counter-terrorism clauses with donors
• Running risk assessments for programmes in high-risk areas
• Designing proportionate partner vetting procedures
• Defending needs-based targeting against inappropriate screening demands
• Preventing and investigating diversion of aid
• Preparing documentation that banks accept
• Advising staff on legal risks in access negotiations
• Linking counter-terrorism risk to staff security planning
• Reporting to boards and donors on residual risk
• Sharing risk fairly with local partners

Strong counter-terrorism risk management systems help organisations:

• Keep funding and banking channels open
• Reach people according to need
• Protect staff and partners from legal and security harm
• Demonstrate accountability to donors and regulators
• Reduce the risk of aid diversion
• Avoid over-compliance that harms principled action
• Respond quickly and consistently to incidents
• Preserve acceptance among communities
• Learn from incidents and improve controls

Strong systems also make advocacy more credible: organisations that document their controls are better placed to ask donors and banks for proportionate treatment.

Who Should Attend This Counter-terrorism Risk Management Training?

This programme is designed for:

• Country directors and heads of mission
• Humanitarian programme managers
• Risk and compliance managers
• Legal advisers and counsel
• Finance directors and treasury staff
• Grants and partnership managers
• Procurement and logistics managers
• Internal auditors
• Safety and security advisers
• Policy and advocacy officers working on humanitarian space
• Staff of National Red Cross and Red Crescent Societies
• Donor agency officers managing humanitarian grants
• Officials from government agencies that fund or coordinate humanitarian aid
• Staff of UN agencies and international organisations
• Board members of humanitarian NGOs

Mid-level and senior staff gain the most, especially when finance, programme and legal colleagues attend together.

Counter-terrorism Risk Management Training Objectives

Upon successful completion of this Counter-terrorism Risk Management Training, participants will be able to:

• Explain how counter-terrorism measures and sanctions interact with principled humanitarian action
• Identify the global, regional and national measures that apply to their work
• Apply UN resolution 2664 and the EU humanitarian exemptions to practical cases
• Analyse counter-terrorism clauses in donor agreements
• Explain the revised FATF Recommendation 8 and what it means for non-profit organisations
• Assess and categorise counter-terrorism related risks across operations
• Design proportionate partner due diligence and anti-diversion controls
• Prepare for discussions with banks on financial access
• Integrate counter-terrorism risk into enterprise risk management
• Link legal risk and staff security in operational planning
• Allocate responsibilities and resources for risk management
• Develop an action plan for their organisation

The objectives reflect both the original scope of this programme and the main changes in law and standards since 2022.

Programme Contents and Structure

Counter-terrorism Risk Management Training Methodology

The programme is interactive and practical. Short presentations are followed by case work, and participants are encouraged to share their own experience under clear confidentiality rules.

The programme combines:

• Expert presentations on law, standards and practice
• Close reading of resolutions, regulations and clauses
• Illustrative case scenarios, clearly labelled
• Risk register and due diligence design exercises
• Group discussion of dilemmas
• Peer exchange between NGOs, UN agencies and donors
• Checklists and templates for immediate use
• Question and answer sessions
• Individual coaching based on the pre-assessment
• Action planning

Before the programme, Risalat reviews each participant’s expectations and current knowledge so the facilitator can focus on the areas that matter most. Teams may also use the free governance audit to review their controls in advance.

Technical Visits and Site Programme

The original programme included an exposure visit, and this is kept. Part of the fifth day is reserved for a technical visit or structured peer exchange with humanitarian practitioners based in Paris, focused on how organisations manage compliance, financial access and principled programming in practice.

Visits are confirmed with host organisations closer to the programme dates and depend on their availability. Where a visit cannot be arranged, a moderated peer exchange with invited practitioners takes its place. Discussions follow the host’s confidentiality rules.

Expected Outcomes

Upon completion of this Counter-terrorism Risk Management Training, participants will be able to:

• Map the counter-terrorism and sanctions measures affecting their operations
• Apply humanitarian carve-outs and document reliance on them
• Negotiate clearer counter-terrorism clauses with donors
• Engage banks with a well-prepared compliance file
• Maintain a risk register with clear owners
• Run proportionate partner due diligence
• Strengthen anti-diversion controls
• Connect legal risk to staff security planning
• Present a resourced risk management plan to senior management

Participants leave with a set of tested templates and a plan they can start using in their next grant cycle.

Institutional Application of Counter-terrorism Risk Management Training

This programme supports organisations in strengthening:

• Risk governance at board and management level
• Counter-terrorism and sanctions compliance policies
• Grant management and donor negotiation
• Partner selection, capacity support and monitoring
• Treasury and banking relationships
• Procurement and cash assistance controls
• Human resources policies
• Security risk management and duty of care
• Internal audit and assurance
• Incident reporting and investigation
• Policy and advocacy on humanitarian space

Participants return with practical tools to improve:

• Counter-terrorism exposure maps
• Risk registers
• Donor clause review checklists
• Carve-out documentation notes
• Partner due diligence procedures
• Bank compliance file outlines
• Anti-diversion checklists
• Incident reporting forms

To place these tools in a wider review of systems, organisations can use Risalat’s free institutional capacity assessment.

Regional Relevance & Application

Africa

The Sahel accounted for more than half of global terrorism deaths in the Global Terrorism Index 2025, and three of the five most affected countries were Sahelian. Humanitarian organisations in the region work alongside sanctions and counter-terrorism laws, and need controls that keep assistance flowing to people in need.

Middle East

Research published with NRC and OCHA on the Occupied Palestinian Territory documented stalled projects and self-censorship linked to counter-terrorism measures, and later studies on the Syria response examined the effect of bank de-risking. Organisations in the region continue to manage complex banking and donor requirements.

Asia

Pakistan was among the most affected countries in the Global Terrorism Index 2025 and was ranked first in the 2026 edition. Agencies operating in parts of South and Central Asia need clear policies on partners, payments and access.

Europe

European donors and NGOs operate under EU sanctions regulations, which since 2023 include humanitarian exemptions, and under national counter-terrorism laws. Many headquarters are in Europe, so policy decisions made there shape field practice worldwide.

Latin America

Humanitarian actors in parts of Latin America also face designated armed groups and financial controls. The same tools for risk assessment, due diligence and bank engagement apply.

Participants adapt the week’s tools to their own legal setting and donor mix.

Host Country Profile – France

Paris is one of Europe’s main centres for international affairs, with good conference facilities and direct air and rail links to much of the world. It hosts the OECD and many international and humanitarian organisations, which makes it a convenient place for practitioners to meet and compare approaches.

France is a relevant benchmark for this topic. The Financial Action Task Force was created at the G7 summit in Paris in 1989, and its secretariat is hosted by the OECD in Paris; FATF revised Recommendation 8 on non-profit organisations in November 2023. In February 2023 the Conseil d’État, France’s highest administrative court, annulled 2021 guidelines from the Ministry for Europe and Foreign Affairs that required screening of final beneficiaries against sanctions lists, after a petition by eight French NGOs coordinated by Coordination SUD. France also publishes a humanitarian strategy for 2023 to 2027.

France is part of the Schengen area. Participants who need a Schengen visa should apply early through the competent French consulate or visa centre; Risalat provides invitation letters and visa advice. Paris is served by two major international airports and an extensive public transport network.

Counter-terrorism Risk Management Training Deliverables

Risalat supports participants before, during and after the programme.

Before the Programme

• Participant Pre-Assessment
• Counter-terrorism Risk Management Readiness Assessment
• Counter-terrorism Risk Management Resource Pack
• Preparatory Reading Materials
• Complimentary Visa Support & Advisory

During the Programme

• Airport Pickup & Welcome Assistance
• Accommodation with Breakfast
• Welcome Networking Dinner
• Risalat Training Kit (Bag, Bottle, Mug, T-Shirt, Cap, Passport Cover, Pens, Notebook, Magnet & Keychain)
• Comprehensive Counter-terrorism Risk Management Training Manual
• Exposure Mapping Template
• Counter-terrorism and Sanctions Risk Register
• Donor Clause Review Checklist
• Partner Due Diligence Procedure Template
• Bank Compliance File Outline
• Practical Workshops & Simulations
• Group Discussions & Peer Learning
• Daily Lunch and Refreshments
• Full Access to Training Venue Facilities
• Mini Pad / Tablet with Digital Learning Materials
• Field Visit (where applicable)
• Entertaining City Tour

After the Programme

• Certificate of Completion
• Risalat Programme Participation Recognition Award
• Post-Training Reference Materials
• Organisational Risk Management Plan
• Sanctions and Carve-out Reference Guide
• Post-Training Support & Follow-Up Guidance
• Programme Report

Institutions can request a tailored in-house version of this programme, adapted to their donors, countries of operation and internal policies.

Common Challenges in Counter-terrorism Risk Management for Humanitarians, And How This Training Helps

How can we tell which counter-terrorism measures apply to our work?

Day 1 and Day 2 show where to find UN, EU and national measures and how to map them against funding, banking, partners and locations, using the exposure mapping workshop.

How do humanitarian carve-outs work in practice?

Day 2 works through resolution 2664, resolution 2761 and the EU regulations, and the case study shows what a carve-out may cover and what still depends on national law and donor terms.

How can we respond when donors ask us to screen beneficiaries?

Day 4 covers the debate on beneficiary screening, the French Conseil d’État ruling and ways to discuss proportionate alternatives with donors while keeping assistance based on need.

How do we keep bank transfers moving to high-risk areas?

Day 3 explains why banks de-risk, what the revised FATF Recommendation 8 expects and how to prepare a compliance file that answers banks’ questions.

How can we vet partners without harming partnerships?

The Day 4 workshop builds a due diligence procedure scaled to risk, with support for partners and fair sharing of risk.

How do we link legal risk with staff security?

Day 4 connects counter-terrorism risk to duty of care, access negotiation and incident reporting, so security and compliance teams work from the same plan.

How do we turn the training into lasting change?

The Day 5 capstone produces a resourced risk management plan, reviewed by peers, that participants take back to management and boards.

Frequently Asked Questions

Is this a security operations course?

No. It is about how humanitarian organisations manage the legal, financial and security risks that counter-terrorism measures and sanctions create for principled aid. It is neutral and non-operational.

What is the humanitarian carve-out?

UN Security Council resolution 2664 (2022) states that providing funds or goods needed for humanitarian assistance does not violate UN asset freezes. Resolution 2761 (2024) extended it to the ISIL and Al-Qaida regime without an end date, and the EU applied it in 2023.

Why does FATF Recommendation 8 matter to NGOs?

Its November 2023 revision requires focused, proportionate and risk-based measures for non-profit organisations, which helps NGOs argue against blanket restrictions and supports better dialogue with banks and regulators.

Who should attend?

Country directors, programme, finance, grants, compliance, legal, audit and security staff of NGOs, UN agencies and Red Cross and Red Crescent Societies, plus donor and government officials who fund humanitarian aid.

Is there a visit during the programme?

Yes. Part of the last day is a technical visit or peer exchange with humanitarian practitioners in Paris, confirmed with host organisations closer to the dates.

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