When the Giving Gets Tough

Navigating Risk in Sanctioned Locations



Executive Summary


This paper aims to provide donors, civil society practitioners, and other stakeholders with an overview of how U.S. sanctions are implemented, the challenges their implementation often poses for civil society organizations, and the risks associated with charitable giving in sanctioned locations—along with strategies for managing those risks.

The first section of the paper examines the legal bases for sanctions, such as the International Emergency Economic Powers Act (IEEPA) and the National Emergencies Act (NEA). It explains the varying types of sanctions, from the broader categories of primary and secondary sanctions, to sub-categories such as comprehensive and limited sanctions. It also explains the different ways sanctions can be implemented, including blocking sanctions that block a targeted person or organization’s interest in property that comes into U.S. jurisdiction, trade and transaction restrictions, and banking restrictions. Lastly, this section unpacks the exemptions and licensing processes, explaining the differences between exemptions, general licenses, and specific licenses.

The second section of the paper addresses the harmful impacts of sanctions on civil society programs. It offers specific examples of the impact of sanctions on humanitarian access, peacebuilding programs, and financial access for civil society organizations. It also explains the challenges with the current licensing process and exemptions, from costs and delays associated with procuring specific licenses, to exemptions that are too narrowly tailored to provide meaningful protection for civil society programs.

The third section of the paper offers examples of the challenges faced by donors that work in sanctioned locations, and offers five key strategies for donors to manage the risks associated with charitable giving in sanctioned contexts. Specifically, it recommends that donors consider:

  • Implementing a risk-based approach to their giving
  • Documenting their due diligence processes Understanding bank policies on fund transfers to high-risk countries
  • Working with an intermediary grantmaker
  • Identifying an alternative grantee


Published in Partnership with the Charity & Security Network


The Charity & Security Network is a resource and advocacy center working to promote and protect the ability of nonprofit organizations to carry out peacebuilding, humanitarian, and human rights missions and to advance national security frameworks that support rather than impede this work. Learn more on C&SN’s website at www.charityandsecurity.org.

Related Resources

White Paper

When the Giving Gets Tough: Navigating Risk in Sanctioned Locations

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