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4. Outreach and practices of the organisation

Humanitarian intervention scope

The data collection framework begins enhancing a better understanding of an organisation's humanitarian scope and range of intervention. Although this data is typically already gathered by the organisation, the granularity offered by the framework ensures a common baseline to facilitate analysis.

Why do we collect this information?

Understanding the extent of the organisation's humanitarian reach – including countries of operation and the types of activities undertaken – will subsequently enable a more comprehensive analysis of the ultimate impact of SCTM. This will be achieved by revealing the potential number of individuals affected by obstacles.

What information do we want to collect?

  • Geographic areas of intervention are expected to be listed at the L1 level. For sensitivity purposes, some areas may be anonymised or renamed at the analysis stage.
  • Sectors of intervention should align with the architecture of the IASC’s & OCHA’s Cluster System.
  • Obtaining figures related to the number of beneficiaries can sometimes pose challenges when it comes to verification. 

This can be even more complex when these figures are disaggregated by sectors and areas of intervention (L1). We recommend using the figures made available in annual reports, as they may be less accurate but easier to collect. When
not available otherwise, approximate breakdowns per sector of L1 areas can be used.

SCTM Related Assets

Irrespective of their distinct missions and operational zones, each humanitarian organisation has developed specialised
resources to operate in volatile environments often characterised by a lack of transparency and numerous sanction constraints. While the specific attributes of each organisation's SCTM related resources can vary based on their distinct mandate and operational ethos, there are shared characteristics across the sector:

Institutional knowledge encompasses the organisation’s expertise concerning the impact of SCTM on humanitarian operations. This includes comprehension of compliance prerequisites, conducting risk assessments, and devising
strategies to navigate the complexities associated with both operating in regions inhabited by designated individuals or groups and the additional complexities of sanctions and counterterrorism regulations. Such knowledge builds up naturally over time through practical experiences, research, and collaborative interactions with other stakeholders. This allows NGOs to effectively respond to the challenges and implications of SCTM while delivering aid and assistance to vulnerable populations.

Mitigation and control measures: while not always specifically designed to prevent unintended humanitarian benefits to designated entities, these assets are often regarded by external counterparts as the most valuable way to curbing such risks. These measures manifest in various forms:

  • Aid diversion policies: Comprehensive risk assessments and management protocols conducted at Country and area level.
  • Internal safeguards: Ethical Codes of Conduct and internal policies, dedicated internal guidelines on counter-terrorism measures and regulations, whistleblowing and complaint mechanisms.
  • Control mechanisms: budget reporting, segregation of duties, due diligence & vetting/ screening mechanisms for personnel, suppliers and partners, bidding processes, traceability of aid distributions, audits.

SCTM-related accountability, despite being spread out throughout the organisation, may represent a substantial workload and consequential costs. This is particularly true as these responsibilities often involve requisites that lie beyond the organisation's primary mandate. These encompass HR fully/ partially assigned to address third-party requests (such as banks or donors’ compliance requirements), but can extend to the use of external expertise (legal services, etc…) or of any other type of external compliance-dedicated asset.

Why do we collect this information?

These assets represent a significant resource commitment and are worth being highlighted for two reasons:

  • Showcasing strong aid traceability and accountability stands as a fundamental protective measure against the introduction of additional and burdensome SCTM-related compliance processes. Institutional knowledge and mitigation/control strategies play a pivotal role in this demonstration.
  • Acknowledging the efforts and expenses linked to external accountability requests allows us to factor in the efficiency setbacks for our organisation – and consequently, our operations – into advocacy opportunities.

Furthermore, a comparative analysis of these assets can potentially unveil disparities in their allocation between HQ and the field, thereby indicating possibilities for corrective measures. 

What information do we want to collect?

Info collection table 1


Engagement with designated non-eligible entities

Assessing the unintended beneficial impact of humanitarian interventions on entities that, in principle, are not eligible for aid, is an important part of understanding operational risks and consolidating advocacy efforts. However, it requires specific precautions and strong internal validation.

Why do we collect this information?

The primary objective of sanctions and counterterrorism measures (SCTM) is to curtail financial and material support to designated or sanctioned groups and individuals. Beyond assessing SCTM’s impact on humanitarian operations, documenting tangible risks and incidents related to aid diversion or benefits to designated entities becomes an
integral part of advocacy endeavours. 

For instance, UNSC Resolution 2664 mandates the Emergency Relief Coordinator (ERC) to present annual verbal briefings to the UN Security Council Sanctions Committees. These briefings encompass data about the provision of funds or economic resources to designated entities and individuals (with the acknowledgment that transfers for
humanitarian activities and basic needs are now permitted under Resolution 2664).

For Member States, the primary aim of this specific report is to evaluate whether easing restriction related to humanitarian actions unintentionally benefits designated individuals and entities. 

In general, the accurate gathering of data concerning non-intended benefits and aid diversion cases is paramount. An unrealistically low number of such instances could undermine the credibility of the overall reporting and consequently weaken wider advocacy endeavours. Hence, a comprehensive data collection approach is imperative to robustly substantiate the impact of SCTM on humanitarian action.

What information do we want to collect?

Info collection table 2


Collecting and analysing information related to aid diversion and unintended benefits for non-eligible actors is extremely sensitive and requires strong risk mitigation precautions within the organisation. For this reason, we strongly recommend direct supervision of this specific data collection section by the Global Senior Management Team (SMT). Additionally, the collection process itself should be carried out by accredited collaborators, such as internal audit teams and desk managers.

It is essential to establish the exact scope of information to be collected and aggregated in advance:

  • What defines a non-eligible entity in the context of the organisation and its country operations?
  • How are payments and benefits to official authorities categorised as humanitarian resource diversion or misappropriation?

The data collection tool provided in this framework offers clarification for each category of unintended benefits. However, the organisation must refine its own interpretation of categories. Ultimately, all analyses and information resulting from this data collection should be reviewed and approved directly by the SMT before being shared externally.

All tools included in this SCTM data collection framework are primarily conceived for a use within the organisation and are not designed for external sharing without prior internal validation by the SMT.

Tool B: Benefits to designated and non-aid eligible entities

Tool type: Survey 

Download the Tool. 

The data collection tool was developed and designed by Action Against Hunger, Médecins du Monde, and Humanity & Inclusion.

Military checkpoint, Palestine. 2020 © Creative Commons Licenses.

5. SCTM-Related issues

This section looks at the impact that donor clauses, screening obligations, and over compliance by banks and the private sector can impact aid delivery and how to manage it.
Learn more