As we come to the end of 2022, at C&SN we want to take this opportunity to share some key accomplishments across our numerous issue areas as we seek to protect and advocate for the essential work of nonprofits (NPOs), and to promote an enabling environment for civil society across the globe. 

C&SN’s Beloved Founder Retires

In March, Kay Guinane, C&SN’s beloved founder and leader for the past 14 years, retired. C&SN, our community, and the field writ large greatly benefitted from Kay’s expertise, commitment, and tireless advocacy to support and elevate the important work of civil society. Kay was a visionary who created opportunities where others saw closed doors. Through years of identifying solutions to the most pressing challenges, building relationships, facilitating multi-country coalitions, creating frameworks of research and data-driven evidence, advocating to institutions, and pushing for legislative and policy change, Kay has made C&SN into the thriving network and resource center that it is today. 

In April, C&SN held a Retirement Party for Kay, to share memories, gratitude, and tributes to her leadership, influence, impact, and dedication to the work. This tribute included an official statement published in the Congressional Record on April 6, which further cements Kay’s legacy and contributions.

The accomplishments and successes that we’ve seen over the course of this year would not be possible without leaders like Kay blazing the trail. 

Landmark Sanctions Protections at the UN and the U.S.

Sanctions, as is documented, are a core inhibitor for effective humanitarian, development, and peacebuilding programs implemented where sanctioned entities are active. 2022 was a historic year for much needed – and long advocated for – changes to how sanctions regimes impact peoples’ lives and hamstring essential civil society work. Below are the significant breakthroughs C&SN helped facilitate this year.

United Nations Security Council Resolution (UNSCR) 2664

At the multilateral level, the UN Security Council adopted Resolution 2664 in December to ensure life-saving humanitarian work is unburdened by UN sanctions. The Resolution was led by the U.S. and Ireland, and established a standing humanitarian carveout within UN sanctions regimes. C&SN, amongst fellow civil society organizations, published a Press Release praising the adoption of this landmark resolution and urging the U.S. to follow suit domestically, namely through the issuance of a Global General License.

The U.S. Implements Humanitarian Protections Across New and Existing Sanctions Regimes

For years, C&SN has been among the chorus of civil society voices calling for an end to sweeping, broad-based sanctions. In particular, C&SN and fellow civil society organizations have called on the Treasury Department to adopt a Global General License to ease the operating landscape for civil society in responding to humanitarian, development, and peacebuilding needs in regions with sanctioned entities. 

In September, C&SN submitted a model Global General License to Treasury, advocating for enshrining explicit protections for legitimate civil society activities in all sanctioned contexts, in addition to providing financial institutions with reassurances that they will not face civil or criminal liability for working with civil society organizations in these contexts. 

In December, these collective efforts were heard. The Treasury Department announced authorization of a series of new or amended General Licenses and four accompanying FAQs, solidifying protections for humanitarian, peacebuilding, and other life-saving activities in areas under U.S. sanctions. C&SN applauds this action, which is the most expansive and comprehensive step Treasury has taken towards a Global General License, and published a celebratory Press Release

These humanitarian exceptions and changes to sanctions regimes, both at the UN and U.S. level, are truly historic and monumental, and most importantly have the potential to enable life-saving humanitarian aid to reach communities and populations most impacted by conflict and disasters, without delays or restrictions. 

Sanctions, Incentives, and Human Security: Economic Statecraft and Humanitarian Crises

Following the May 2022 Wilton Park Conference, in which C&SN Director Paul Carroll participated, Wilton Park, in partnership with the Fourth Freedom Forum and the Sanctions & Security Research Project, released a report summarizing key takeaways from the event. There was broad consensus that sanctions continue to create unacceptable humanitarian and other consequences for innocent populations. 

Advocating for Financial Access of NPOs 

One of the core challenges NPOs face while working in conflict zones and sanctioned areas, is that existing counter-terrorism measures cause a chilling effect on financial institutions, who may de-risk their NPO clients working in these regions to avoid violating sanctions and overly burdensome anti-money laundering and countering the financing of terrorism (AML/CFT) measures. This has been a key area of advocacy for C&SN for years, and 2022 yielded further progress in protecting and advocating for the rights of financial access of frontline NPOs.

U.S. Multi-stakeholder Working Group on Financial Access (MSWG)

C&SN partook in the second iteration of the U.S. MSWG, facilitated by the Center for Strategic and International Studies (CSIS), held from 2021 – 2022, which brought together stakeholders from the financial, government, and non-profit sectors to address challenges to financial access for NPOs and explore collective solutions. 

Within this working group, C&SN co-led the Workstream on Due Diligence with the Bank Policy Institute (BPI), which built relationships across the three actors, and highlighted NPOs’ existing compliance and due diligence measures. It aimed to find collective solutions to address ongoing de-risking challenges, including unpacking why financial transactions are delayed or rejected; to streamline communication channels between banks and NPOs; to understand how to lessen the compliance risks and regulatory reviews banks; and to ensure financial institutions apply a risk-based approach (RBA).

C&SN supported the development of the policy proposals presented in the final report, Mitigating Financial Access Challenges: Proposals from the CSIS Multi-stakeholder Working Group on Financial Access.

Global NPO Coalition on the Financial Action Task Force (FATF)

C&SN co-founded the Global NPO Coalition on FATF in 2014 and has served on the Core Leadership Group since its inception. Throughout 2022, C&SN collaborated with Coalition members on monitoring FATF’s unintended consequences workstream. As part of this workstream, C&SN submitted comments on FATF’s Best Practices Paper on Combating the Abuse of NPOs (Recommendation 8) and worked with Coalition partners to submit comments on the draft Guidance on R.24 and potential amendments to R.25 (Beneficial Ownership).

In October, C&SN moderated a UN General Assembly side event on Countering the Misuse of Counter-terrorism Financing Measures” hosted by the Permanent Mission of Ireland to the UN. The event served as the formal launch of the Special Rapporteur’s position paper on The Human Rights and Rule of Law Implications of Countering the Financing of Terrorism Measures

Panelists traced the evolution of State practices stemming from the applicable international legal framework, such as soft law standards like the FATF recommendations, the Treaty on Suppression of the Financing of Terrorism, and Security Council Resolutions 1373 and 2462. Finally, recent challenges to State compliance and collaborative solutions to the current accountability gap were identified. 

Global Hub on AML/CFT

As a member of the Global Expert Hub on AML/CFT, C&SN was among a group of 70 activists and civil society organizations from 45 countries attending the “AML/CFT Hub Reconnected Workshopnear Paris in September. The workshop unpacked engagement strategies for the ongoing revision of key FATF standards at the country, regional, and international level. De-risking challenges and solutions were discussed amongst participants, as were emerging trends, challenges, and impacts surrounding the  utilization of digital technology in AML/CFT measures.  


In 2018 CS&N began working on countering the use of legal tactics to advance, political agendas. Beginning around 2014, a handful of groups with political agendas have impeded the valuable work of NPOs through lawsuits, deplatforming campaigns, challenges to organizations’ tax-exempt status, and other means. Called “lawfare” attacks, these organizations typically support a particular government and act in ways that support that governments policies. Although these groups claim their actions are aimed at strengthening security, they stand in the way of NPOs’ legitimate work. In 2022, C&SN continued to raise awareness on these politically motivated attacks in order to protect NPOs around the world.

EuroMed Rights Workshop: the Impact of Counter-terrorism on Civil Society

In October, C&SN delivered a presentation on the Alarming Rise of Lawfare to Suppress Civil Society at the workshop session highlighting “The use of counter-terrorism measures to target civil society organisations and human rights defenders: a global overview” at the “EuroMed Rights Workshop” in Brussels. The presentation gave visibility to issues around shrinking civil society space and drew upon C&SN’s Lawfare Report to show how actors besides governments can present threats to civil society and human rights practitioners. 

C&SN Panel Discussion: Tracking the Suppression of Palestinian Civil Society and Human Rights Advocacy

In October, C&SN hosted a panel that examined a range of strategies that the Israeli government and allied organizations have employed to suppress Palestinian civil society and human rights advocacy, and looked at some of the broad efforts and opportunities for pushing back against these strategies. 

C&SN moderated the panel alongside expert panelists Sahar Francis, General Director of Addameer; Rabea Eghbariah, Human Rights Lawyer with the Civil and Political Rights Unit at Adalah; and Lara Friedman, President of the Foundation for Middle East Peace. The panel built off of C&SN’s report, The Alarming Rise of Lawfare to Suppress Civil Society: The Case of Palestine and Israel, which covers a long list of legal and disinformation campaigns targeting civil society in Palestine. Watch a recording of the webinar on Zoom here (Passcode: u&a4%p=C). 

Amicus Brief in Anti-Terrorism Act (ATA) Case 

In December, in cooperation with attorneys from the Freshfields law firm, C&SN signed on to an amicus brief in the case of Taamneh vs Twitter. This case, filed under the ATA, is significant because depending on the outcome, secondary liability may be found valid for holding organizations legally responsible for supporting terrorism. The implications for civil society organizations are substantial. The case will be heard in February 2023.

Other Accomplishments in 2022

Civil Society Coalition on Human Rights and Counter-terrorism (CT)

C&SN continues to be a proud member of the “Civil Society Coalition on Human Rights and Counter-terrorism (CT)”. In July, C&SN  attended the Coalition’s Strategy Retreat and is now co-leading the Coalition’s CFT and Gender Workstreams. 

As part of C&SN’s work with this Coalition, C&SN participated at the United Nations High-Level International Conference on Human Rights, Civil Society and Counter-Terrorism, held in May in Málaga, Spain. C&SN delivered remarks from the floor on engaging civil society as equal partners in implementing human rights-based approaches to counter-terrorism and spoke to the need to translate UN and Member State commitments into action.

SPAN Annual Conference

In October, C&SN co-facilitated a session at the Security Policy Alternatives Network (SPAN) conference in Berlin. SPAN is an international network of civil society activists and advocates that promote de-militarized and de-securitized alternatives to current security policies. Alongside Sally Mboumien, the Executive Director & Founder of the Common Action for Gender Development (COMAGEND) in Cameroon, C&SN co-facilitated a session on integrating gender and intersectional principles and practices throughout SPAN’s work. 

C&SN also contributed to the conference’s key themes: counter-terrorism impacts on civil society space and on human rights; reclaiming civil society space in authoritarian regimes; responding to trends and risks of militarization; the global implications of Russia’s invasion of Ukraine; and engaged in an advocacy meeting with German policymakers on the forthcoming German National Security Strategy. 

Thought Leadership

Throughout the year C&SN further established itself as a thought leader at the intersection of nonprofit rights and national security through the publication of the following op-eds.

The Global War on Terror Doubles As a War on Peacebuilding – Inkstick
C&SN’s Associate Director for Policy and Advocacy, Ashleigh Subramanian-Montgomery, reflects on the impacts of the Global War on Terror on peacebuilding and humanitarian work, and calls on policymakers to muster the political courage to pursue appropriate policy changes. Read the full piece on Inkstick.

Israel’s West Bank Ordinance: The Latest Effort to Suppress Palestinian Civil Society – Just Security
C&SN Director Paul Carroll unpacks the implications of an Israeli government ordinance that was slated to go into effect in July 2022 that would further a longstanding campaign to undermine Palestinian civil society. Read the full article in Just Security.

US Is Effectively Stealing Billions From a Nation Ravaged by a US-Initiated War – Truthout
C&SN Associate Director for Policy and Advocacy, Ashleigh Subramanian-Montgomery, offers her analysis of the Biden administration’s decision to effectively steal Afghanistan’s foreign reserves by setting aside half for the families of 9/11 victims and half for humanitarian purposes. Read the full article in Truthout.