By Kay Guinane

The ongoing Covid-19 pandemic has forced us all to change the way we work and live, but it poses particularly difficult challenges for civil society organizations that work on the front lines of disaster, conflict and poverty in all parts of the world. Whether these nonprofit organizations (NPOs) are providing direct services in the field, tracking trends or advocating for resources to support those in need, all are rethinking their pre-pandemic priorities and redirecting their work as needed. That includes the Charity & Security Network.

Our mission is to promote and protect NPOs’ ability to carry out effective programs that promote peace and human rights, aid civilians in areas of disaster and armed conflict and build democratic governance. The Covid-19 pandemic has shined a spotlight on many long-standing barriers NPOs continue to face when carrying out this work, particularly from national security related restrictions. The pandemic has exacerbated these problems and created new ones. As the first responders to crisis in many parts of the world, NPOs need support from all stakeholders to eliminate these obstacles.

The pillars of counterterrorism strategy – sanctions, the prohibition on material support of terrorism, and financial restrictions – threaten to inhibit effective pandemic response. Swift action is needed to avoid catastrophic consequences. As one of our members told us:

“Universal public health advice is for people to isolate themselves, wash their hands regularly and practice social distancing as key ways to save lives. For densely populated areas, like Gaza and refugee/IDP communities the world over, this is simply unattainable. Most of these people live in very close proximity to each other. Keeping 2 metres apart will be next to impossible and access to clean water is limited. With hospital or healthcare systems either absent or close to collapse, this virus will cause carnage unless existing conflicts are ‘paused’ and the international community prioritises humanitarian assistance over risk aversion.” (emphasis added)

What the Charity & Security Network is doing to support civil society during the pandemic

Governments and the UN must swiftly remove barriers to aid delivery, support a pause in armed conflict and protect basic rights if spread of the virus is to be contained. C&SN’s Advisory Board and membership have been assessing the situation and have identified key priorities for our work:

  • Sanctions Relief to Save Lives

Sanctions programs of all kinds must be lifted, at least temporarily, to allow full and unimpeded flow of medical supplies and basic necessities to areas in need. The complex web of sanctions programs has created red tape and conflicting standards that lead to inadequate humanitarian response. The virus does not care whether or not the person it infects lives in Iran or northern Nigeria in an area controlled by Boko Haram. When it comes to providing prevention and treatment, neither should governments. The exemptions and licenses currently in place in the U.S. are insufficient to meet the need. There are multiple calls to lift sanctions, including by the UN Secretary General,  members of Congress and more than 70 civil society organizations (including C&SN) that sent a letter to the Trump administration calling for immediate action.

C&SN is making advocacy for comprehensive sanctions relief during the pandemic a priority, for as long as necessary.

  • Protecting Financial Channels

Financial institutions must promptly facilitate payments for essential medical and humanitarian supplies. Government must support their efforts with clear guidance that assures financial institutions they will not be punished for minor or inadvertent violations of sanctions or banking regulations. As one member told us, banking problems make “ the quick and efficient transfer of funds to local organizations to buy supplies and directly to beneficiaries as part of cash programming very challenging. And in sanctioned countries, it is almost impossible to implement humanitarian relief at the speed it is needed.”

On April 23, C&SN published an open letter to U.S. bank regulators calling on them to update the nonprofit section of the Bank Examination Manual. Studies have shown the current version contributes to a regulatory environment that discourages banks from serving NPOs that work in areas of high need and high risk. C&SN will continue pushing for changes in regulatory policy and financial institution action to address the current fund transfer delays.

  • Respect humanitarian and human rights legal obligations

As governments move to arrest spread of the pandemic, they must also avoid restrictive measures that increase suffering and conflict. That means respecting humanitarian principles with rules that do not discriminate in aid access on the basis of politics or location. It also means not imposing disproportionate limits on freedoms of expression, assembly and association, and lifting measures necessary to protect public health when they are no longer necessary. This is an issue of growing concern, as countries such as Iraq and Hungary have already taken advantage of the pandemic crisis to clamp down on dissent and limit civic rights. (The International Centre for Not-for-Profit Law has set up a tracker that details these restrictions.)

C&SN is monitoring action taken by the U.S. government and will respond as needed to ensure pandemic response respects international humanitarian and human rights law.

What our members are telling us about restrictions on their work and the impact on beneficiaries

We asked our members about the impact of government measures on their response to Covid-19. Here is some of what we heard:

  • Pre-existing legal restrictions such as sanctions, licensing, donor requirements and the prohibition on material support of terrorism are complicating their efforts.

One group cited “the inability to act quickly to help in the humanitarian response without fear of criminal sanctions/penalty.” Another said, “The ambiguity around what constitutes material support to proscribed organisations and the threat of false claims prosecutions in certifications made in USAID contracts makes working in any conflict and fragile state environment very challenging. This will be the same as we try to respond to Covid-19 in those areas. These, by definition, contain some of the most vulnerable and least-prepared communities, but are also areas where proscribed groups operate and often control local resources. This can make essential procurement a risky business and cause INGOs to hesitate just when the need is greatest.”

  • New restrictions enacted to contain Covid-19 are having unintended side effects for aid delivery.

Nearly every group we heard from said that travel restrictions, quarantine measures and special measures put in place to combat the virus have also made it more difficult for them to do their jobs. One group noted that, “The travel restrictions/lockdown and lack of exemptions for humanitarian workers makes interventions more difficult.”

  • Restrictions on NPOs is resulting in reduced or lost access to essential services.

Both pre-existing and new restrictions on NPOs are already having a negative impact on program services, with well over half the responses citing significant reduction in services.


As “first-responders” that provide vital medical, humanitarian and protection services, civil society is key to an effective response to the Covid-19 crisis. But it is hampered by both pre-existing and new restrictions that get in the way of prompt and effective delivery of services. Governments, banks and all stakeholders must act quickly to lower these barriers. As one of our members said, “All restrictions, some understandably necessary, will clearly further restrict humanitarian access. It is imperative that humanitarian exemptions are now agreed to access particularly vulnerable populations.”