The humanitarian situation in the Middle East region is rapidly deteriorating, with military strikes and communications shutdowns disrupting aid delivery, displacing communities, and damaging civilian infrastructure.
Civil society organisations, often the first responders to a crisis, have to operate under these conditions and are expected to deliver lifesaving aid while their funding channels, financial transfers, and operational capacity are being constrained or obstructed by either banks or regulators or both.
It is crucial that access to financial systems is guaranteed for aid-providing organisations, and anti-money laundering and counter-terrorism financing (AML/CTF) frameworks don’t become unnecessary obstacles to humanitarian aid.
Principles to use in crisis response
In 2022, upon the onset of the Russian aggression and ensuing war in Ukraine, governments, financial institutions, civil society organisations and international bodies discussed a critical tension: how can we avoid that the rules protecting financial integrity, necessary and important as they are, become obstacles to humanitarian aid in times of multiple and evolving crises?
The result was the Tbilisi Principles: core commitments with concrete recommendations for every sector, designed to help all actors prepare for and respond to humanitarian emergencies.
We call on all governments, financial institutions, donors and civil society organisations to revisit the Tbilisi Principles and to act on them in the ongoing Middle East crisis.
Why the Tbilisi Principles apply
Each of the principles speaks directly to what is now being tested:
1. Civil society is irreplaceable as a first responder.
- Where governments face diplomatic constraints and international agencies face access restrictions, local and international organisations are often the only actors who can reach people and deliver critical aid.
- Treating them as inherently high-risk for financial abuses or burdening them with disproportionate compliance in their urgent operations is not a neutral regulatory act – in practice, it means delayed aid and lost lives.
2. Risk tolerance must sometimes be temporarily recalibrated.
- The principles don't call for abandoning AML/CTF obligations. They call for applying the risk-based approach as intended: proportionately.
- The Middle East crisis differs in geography and politics from Ukraine, but the financial integrity challenges humanitarian groups face are identical.
3. Adjustments to the institutions' risk tolerance should be deliberate and pre-agreed.
- When adjustments to institutions' risk tolerance are made ad hoc and under pressure, without clear frameworks, sunset clauses, or accountability, they are rarely fit for purpose and can be too slow to matter or too broad to be safe.
- Response by banks and regulators can be structured and in line with a proportionate approach as proposed under the Tbilisi Principles by following the recommendations outlined below.
What needs to happen now
The Tbilisi Principles include concrete recommendations that can be applied now:
- Governments / competent authorities: convene multi-sectoral humanitarian response groups now; assess whether temporary risk appetite adjustments are warranted; communicate clearly to financial institutions.
- Financial institutions: formally assess whether the crisis warrants temporary increased risk tolerance; simplify the onboarding for relief or help organisations; remove fees for crisis-affected account holders.
- Donors: make proportionate adjustments to existing grant conditions without delay; offer budget flexibility, timeline extensions and simplified reporting.
- Financial Action Task Force and regional bodies: issue specific guidance for this crisis context; disseminate it urgently to member states.
- Civil society: introduce, document and communicate compliance measures to banks and competent authorities.
Governments, financial institutions, funders and civil society all have a role to play: follow the Tbilisi Principles and work together to deliver aid without delay.
The Tbilisi Principles (2022) were developed at the conference on the 'Consequences of the Ukraine Invasion on the AML/CFT regime for NPOs in the Eastern Partnership', in Tbilisi, Georgia between 7–9 June 2022, hosted by ECNL, the EU AML/CFT Global Facility, the Institute for Development of Freedom of Information in Georgia and the Global NPO Coalition on FATF.