This toolkit is designed to help you identify counterterrorism-related risks so that your organisation can manage and mitigate these. It aims to make risk management approaches accessible to a broad range of staff who can use these in their day to day work. Before you get started, we recommend you read “Introduction to the toolkit”.
This toolkit will help you to:
- Develop your understanding of counterterrorism measures and how they can impact principled humanitarian action
- Identify potentially problematic wording related to counterterrorism that appears in grant agreements
- Engage with donors to discuss counterterrorism clauses, and develop an internal process for decision making on whether and how to proceed with funding opportunities that pose risks related to counterterrorism measures.
- Increase your understanding of practical aspects of risk management and steps your organisation can take to strengthen its policies and practices, while maintaining a principled approach.
- Enable your organisation to mainstream consideration of counterterrorism related risks throughout the project management cycle.
This toolkit is designed for:
- Staff responsible for partnerships with donors
- Staff involved in programme planning and implementation
- Staff with risk management responsibilities, including those focused on security, humanitarian access, and legal advice
- Policy staff
- Support staff
- Decision-makers
1. Introduction to the toolkit
Risk categories and operational impacts
2. Counterterrorism measures & principled humanitarian action
Where do counterterrorism measures come from?
International level
– UN Security Council
– Info box: What is a humanitarian exemption?
– Financial Action Task Force
– Info box: FATF and bank derisking
Regional level
Domestic level
– Case study: UK Counterterrorism and Border Security Act
– Info box: Host country counterterrorism measures
– Info box: Impact of counterterrorism measures on CVA
Counterterrorism measures and principled humanitarian action: what are the risks?
Risk categories and operational impacts
– Case study: Risks related to indirect support to a DTG
3. Counterterrorism clauses & partnerships agreements
Where are counterterrorism clauses found?
Understanding counterterrorism clauses
Processes for understanding and addressing counterterrorism clauses
– Info box: NPA v USA
– Info box: Vetting and screening
– Case study: Advocacy and principled partnership conditions
4. Counterterrorism & risk management frameworks
Why use a risk management framework?
What are the components of a risk management framework?
1. Identification
2. Assessment
– Info box: Risk mitigation and programme criticality
3. Monitoring
4. Reporting
– Info box: Three lines of defence model
– Info box: Sanctions compliance programmes
Internal controls and risk management
Developing a counterterrorism policy
Developing an NSAG engagement policy
Due diligence
Human resources policies
Anti-diversion policies
M&E frameworks
PCM and counterterrorism risks