Charities operating in the Middle East: guidance and support for trustees
Source: gov.uk (2025-07-23)

Support and guidance for charities undertaking lifesaving work under challenging circumstances in the region.

The following guidance is designed to help enable charities working in the Middle East navigate incredibly complex circumstances as safely and effectively as possible.

This collection of guidance signposts information from across government to help charities assess and manage the risks they face, enabling them to make informed decisions when delivering their life-saving work.

The situation in the Middle East is complex and fluid. Charities are often operating in multiple jurisdictions and in multi-donor environments and we understand this presents numerous challenges for those delivering critical work in this area and those preparing to respond as soon as conditions allow.

This guidance does not represent new requirements for charities: the Commission has drawn together existing content from across government to summarise this in one place. As with all such guidance, charities should apply it in the context of their own operations.

Trustee duties

Our guidance the essential trustee (https://www.gov.uk/government/publications/the-essential-trustee-what-you-need-to-know-cc3) explains the key duties of all trustees of charities in England and Wales, and what they need to do to carry out these duties competently.

Managing risk

Given the changeable nature of the area, it is vital that trustees remain alive to the risks that affect their charity. Read and follow our guidance on managing risks when working internationally (https://www.gov.uk/guidance/charities-how-to-manage-risks-when-working-internationally) for support.

Your charity must operate within UK law and, when operating abroad, you have to understand and comply with local laws. Make sure you understand the consequences of breaking these. Make sure that anyone operating in these areas is fully informed.

For support in identifying and effectively managing the risks use our guidance on charities and risk management (https://www.gov.uk/government/publications/charities-and-risk-management-cc26).

Be alert to financial sanctions

All UK nationals and legal entities established under UK law, including charities, must comply with UK financial sanctions, wherever in the world their activities take place.

The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, helps ensure financial sanctions are properly understood, implemented and enforced in the United Kingdom.

OFSI publishes a list of all individuals and entities subject to financial sanctions in the UK and has produced guidance on financial sanctions for charities and non-governmental organisations (https://www.gov.uk/government/publications/financial-sanctions-guidance-for-charities/financial-sanctions-guidance-for-charities-and-non-governmental-organisations-ngos). You can also read 4 things charities need to know about financial sanctions (https://ofsi.blog.gov.uk/2020/11/13/4-things-charities-need-to-know-about-financial-sanctions/) for more information on what sanctions are and what charities need to know about them.

You must check whether individuals or organisations you are dealing with (for example donors, partners, contractors or beneficiaries) are subject to financial sanctions and to take appropriate action. Check the list of individuals and entities subject to financial sanctions (https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets).

Terrorism and proscribed organisations

The threat posed by terrorism and terrorist groups is ever evolving, and charities must remain vigilant to the risks posed by terrorist groups.

Trustees must take reasonable steps to protect their charities from wrongdoing and harm and minimise the risk of terrorist or extremist abuse. This includes avoiding supporting a proscribed group inadvertently. Read our compliance toolkit on charities and terrorism (https://www.gov.uk/government/publications/charities-and-terrorism/compliance-toolkit-chapter-1-charities-and-terrorism) for detailed information on terrorism, the risks charities face and how you can protect your charity.

The Home Office and the Office of Financial Sanctions Implementation’s have produced joint guidance on operating within counter-terrorism legislation, counter terrorism sanctions and export control (https://www.gov.uk/government/publications/operating-within-counter-terrorism-legislation/for-information-note-operating-within-counter-terrorism-legislation) for information that may be of relevance to charities and NGOs delivering development and humanitarian assistance in high-risk jurisdictions.

A proscribed organisation is a group concerned in terrorism (for example, it promotes or encourages terrorism) and prohibited by law from operating in the UK. It is a criminal offence for a person to belong to, or invite support for, a proscribed organisation. It is also a criminal offence to arrange a meeting in support of a proscribed organisation or to wear clothing or carry articles in public which lead people to suspect that an individual is a member or supporter of the proscribed organisation.

A full list of proscribed terrorist groups or organisations (https://www.gov.uk/government/publications/proscribed-terror-groups-or-organisations--2) with a brief explanation of each is available on the Home Office’s website.

The National Crime Agency’s (NCA) guidance Requesting a defence under the Proceeds of Crime Act 2022 and the Terrorism Act 2000 (https://www.nationalcrimeagency.gov.uk/who-we-are/publications/717-requesting-a-defence-under-poca-and-tact/file#:~:text=Section%2021ZA%20enables%20a%20person,that%20no%20offence%20would%20arise.) provides advice and support if you submit a Suspicious Activity Report (SAR) or if you are seeking a defence (or consent) from the NCA.

Read the Crown Prosecution Service’s guidance on Humanitarian, Development and Peacebuilding Work Overseas (https://www.cps.gov.uk/legal-guidance/humanitarian-development-and-peacebuilding-work-overseas).

Know your donors and partners

All charities should know their donors and assess any risks of accepting donations. Read our guidance Know your donor – key questions for trustees (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/550694/Tool_6.pdf) for support with this.

There will be similar considerations for working with partners or contractors. You should ensure that the individuals or organisations that the charity funds, or uses to help deliver its work, are suitable and appropriate for the charity to associate with. Read our guidance Know your partner - key issues to think about (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/550697/Tool_8.pdf).

Whether you are considering new partners, or reviewing existing partnerships, ensure there is appropriate and proper due diligence to assess the risks. Our guidance Charities: due diligence, monitoring and verifying the end use of charitable funds (https://www.gov.uk/government/publications/charities-due-diligence-checks-and-monitoring-end-use-of-funds) provides more information.

Banking and moving money

We expect charities to use the formal, regulated banking system where possible given the strong safeguards this provides. However, we understand that this is not always possible for a variety of reasons.

If a charity needs to use other methods, then trustees should help manage the risk by having clear policies on when alternative banking methods can be used and what extra financial controls must be followed.

Read our guidance Charities: holding, moving and receiving funds safely (https://www.gov.uk/government/publications/charities-holding-moving-and-receiving-funds-safely) and Internal financial controls for charities (https://www.gov.uk/government/publications/internal-financial-controls-for-charities-cc8) for information on how to manage this risk.

Safeguarding

Protecting people and safeguarding responsibilities are a fundamental part of operating as a charity for the public benefit.

Operating safely and effectively in areas with weak infrastructure or conflict zones is incredibly complex, as is providing support to those impacted by conflict. But it is critical that charities protect and safeguard their beneficiaries, volunteers and staff. You can read:
- our safeguarding guidance for charity trustees (https://www.gov.uk/guidance/safeguarding-duties-for-charity-trustees), to ensure that you take reasonable steps to protect from harm all those who come into contact with your charity
- our guidance on how to manage risks when working internationally (https://www.gov.uk/guidance/charities-how-to-manage-risks-when-working-internationally), to ensure you are identifying and managing the risks to your charity
- the Department for Culture, Media and Sport guidance on handling safeguarding allegations in a charity (https://www.charitysafeguarding.dcms.gov.uk/)
- the Foreign, Commonwealth and Development Office (FCDO) guidance on safeguarding against sexual exploitation and abuse and harassment (SEAH) in the aid sector (https://www.gov.uk/guidance/safeguarding-against-sexual-exploitation-and-abuse-and-sexual-harassment-seah-in-the-aid-sector)
- the FCDO foreign travel advice (https://www.gov.uk/foreign-travel-advice) and monitor and assess any updates to that advice
Organising or participating in aid convoys

There are often inherent risks associated with convoys, including around safeguarding, terrorism, and fraud and theft. The Commission has previously seen a number of charities fail to adequately manage the risks associated with aid convoys, especially when operating in, or close to, conflict zones.

Trustees should therefore consider whether they have the necessary expertise and understanding to ensure safe delivery, and if it is the most effective way to get aid to those in need.

Aid convoys may be restricted in some areas of the Middle East and you should check the FCDO’s foreign travel advice (https://www.gov.uk/foreign-travel-advice) for information on entry requirements and restrictions and check sources of other support at an early stage if you are considering providing support. You will need to frequently check these requirements as they can change quickly: sign up for email alerts from the FCDO to know when the page is updated. You can do this at the bottom of the webpage you are interested in.

Charities that appeal for or purchase medicines should also be aware of, and ensure they are compliant with, the relevant regulations. For more information, please see the Medicines and Healthcare products Regulatory Agency (https://www.gov.uk/government/organisations/medicines-and-healthcare-products-regulatory-agency).

Fundraising and appeals

Our guidance about emergency appeals (https://www.gov.uk/government/publications/disaster-appeals-charity-commission-guidance-on-starting-running-and-supporting-charitable-disaster-appeals-cc40) explains how your charity can help when responding to an emergency. It includes advice about collaborating with other charities and managing risks when planning an appeal.

When fundraising you must ensure that you comply with your trustee duties and fundraising laws. The Fundraising Regulator (https://www.fundraisingregulator.org.uk/) oversees the voluntary Code of Fundraising Practice which sets standards that apply to fundraising carried out by all charitable institutions and third-party fundraisers in the UK. It also has other helpful guidance on setting up appeals.

The Disasters Emergency Committee (DEC), a coalition of 15 leading UK charities, has launched its collective Middle East humanitarian appeal (https://www.dec.org.uk/appeal/middle-east-humanitarian-appeal) and many other registered charities are also helping to provide vital services to those in the area.

To find charities helping in relevant areas, you can search the public Register of charities (https://register-of-charities.charitycommission.gov.uk/).

Keep an eye on our Charities Engagement Team Events (https://bookwhen.com/cetevents) for upcoming events we are holding which may interest you.