Introduction

The Norwegian Refugee Council (NRC) is one of the largest and most influential humanitarian organizations in the world.  With an annual operating budget of over $600 million, the NRC operates in approximately 40 countries around the world.

In recent years, the US has greatly increased support for the organization, providing over $285 million since 2021.

The NRC’s influence is not merely a product of its provision of aid, but the organization often serves as a coordinator of multi-lateral projects, coordinating between numerous donors, international NGOs, UN agencies, local implementing partners, and governmental bodies. As such, the organization is uniquely positioned to influence humanitarian standards and practices for both aid agencies, as well as donor governments and international bodies.

As detailed in this report, NRC consistently advocates that the US and other Western donors to prioritize access for humanitarian organizations over anti-terror considerations. Similarly, it lobbies Federal agencies to change policy to reduce anti-terror vetting standards, as well as helping to develop mechanisms to circumvent them.

The report is divided into five sections.  First, it presents NRC’s guiding principles, and opposition to anti-terror vetting and regulations. Secondly, it presents related NRC advocacy and operations pertaining to Gaza and Yemen. Thirdly, the document review NRC’s relationship with the US, including condemnation of US policy, lobbying for changes to anti-terror regulations, and US funding. Then, it addresses NRC’s desire to work with human rights abusers and US adversaries, including Russia, China, and Iran. Lastly, the report notes NRC’s anti-transparency efforts.

NRC’s “humanitarian principles”

NRC claims that the four humanitarian principles – humanity, impartiality, independence and neutrality – guide and animate its operations. Its definition of independence is critical to understanding its relationship to anti-terror regulations: “To remain independent from political, economic, military or other non-humanitarian objectives.”

In practice, this means that NRC prejudices its own self-defined “humanitarian objectives” over critical policy considerations, including donor concerns that taxpayer-funded assistance will benefit terrorist organizations and local militias.

Often absent from NRC publications is any consideration for the humanitarian and human rights value of denying support to these groups.  Anti-terror regulations are portrayed as onerous and often illegitimate demands from donors, not tools to shorten conflicts, prevent human rights abuses and humanitarian crises, and other negative outcomes.

NRC position on anti-terror vetting

NRC Secretary-General Jan Egeland at a December 2020 conference organized by the French Ministry for Europe and Foreign Affairs: “Exemptions from counter-terrorism laws and sanctions regimes…We need blanket humanitarian exemptions.”   He added, “We need you to champion that there will be no vetting of the ultimate beneficiaries of humanitarian relief.”

Anti-terror regulations seek to mitigate the potential that aid intended for innocent civilians will be commandeered by terrorists and other armed groups, extending conflicts and exacerbating humanitarian crises.  As various studies and conflicts have demonstrated, a variety of aid diversion tactics are employed by terrorist organizations seeking to acquire equipment, supplies, funds, and other material support.

NRC has been one of the leading international campaigners against donor-imposed anti-terror vetting regulations.  This extends both to provisions related to access – demanding that aid NGOs be allowed to engage with proscribed groups – as well as to the selection of local partners and beneficiaries.

NRC is ideologically opposed to these restrictions, believing that humanitarian actors – and they alone – should be entrusted with making determinations regarding what aid should be delivered, to whom, and how.  While crucial components in denying support to organizations that seek to harm civilians and promote conflict, NRC often portrays anti-terror mechanisms as “political,” and therefore, illegitimate.

A joint 2013 NRC-UN Office for the Coordination of Humanitarian Affairs (OCHA) report, “Study of the Impact of Donor Counter-Terrorism Measures on Principled Humanitarian Action,” plainly articulates this fundamental position:

  • “Donor States and inter-governmental bodies should avoid promulgating on-the-ground policies that inhibit engagement and negotiation with armed groups, including those designated as terrorist, that control territory or access to the civilian population.” (emphasis added)
  • “Some administrative counter-terrorism measures not only consume resources but lead to real or perceived violations of humanitarian principles. The practice of partner vetting, in some of its manifestations, is one of these. The practice is a cause for concern where it is used to exclude beneficiaries in need on non-humanitarian grounds, or where it undermines the neutral image of humanitarian actors.” (emphases added)
  • “As indicated earlier, the basic principle that humanitarian action must be undertaken solely on the basis of need, without discrimination on political or other grounds, requires the fact of terrorist designation or other links to be ignored when dealing directly with individual beneficiaries. When an individual is in need, assistance which aims at preserving life, preventing and alleviating human suffering and maintaining human dignity cannot be denied. Any potential security disadvantage from such an act, for example where it is seen as helping the enemy, is considered to be outweighed by the humanitarian imperative in this situation.” (emphases added)

Similarly, NRC’s 2018 “Principles Under Pressure, report, focusing on “the impact of counterterrorism measures and preventing/countering violent extremism on principled humanitarian action,” advances the same agenda. The publication asserts that “There is clear tension between the counterterrorism measures set out in legislation and donor requirements, which may restrict engagement with DTGs [designated terrorist groups], and principled humanitarian action, which requires engagement with all parties to a conflict in order to reach those in need.”

In 2020, NRC published a “toolkit,” promoting “best practices” for navigating challenges presented by anti-terror requirements.  In it, the organization reaffirms its position that it should be allowed to engage with terrorist organizations, and rejects vetting of beneficiaries to ensure that they are not affiliated with proscribed terror groups:

  • “Engaging with non-state armed groups (NSAGs), regardless of whether they are DTGs [designated terror groups], is a key element of gaining and maintaining secure access to people in need.” (emphases added)
  • “Vetting of beneficiaries is a red line for many humanitarian organisations because it could lead to organisations selectively responding to the needs of affected populations, withholding assistance from certain potential beneficiaries rather than providing assistance on the basis of needs alone…To ensure an impartial response, affiliation with political, or other groups, does not form part of the selection criteria.” (emphases added)
  • A checklist that appears as part of the toolkit, implores NGOs not to accept funding if its counter-terrorism provisions would “have negative effects on your organisation’s reputation and acceptance among beneficiaries, host communities and others.”

NRC’s position on terror groups in Gaza and Yemen

NRC supporting Hamas involvement in aid

NRC has long campaigned for direct Hamas involvement in aid distribution in Gaza.

In 2006 it called on the Norwegian government to “support Hamas as the democratic elected government and not impose actions that lead to more instability.”

In its joint 2013 publication with OCHA, NRC laments the fact that donor government restrictions limit its contact with the terrorist organization:

“The parameters of humanitarian action have for the most part been shifted so that programmes are designed firstly to avoid contact with or support to the designated group (Hamas) and only secondly to respond to humanitarian needs… This distortion of the core humanitarian principle of impartiality is one of the key fears of those concerned about the impact of counter-terrorism measures on humanitarian action.”

However, while complaining that the level of engagement is insufficient, NRC acknowledges that they and other humanitarian actors coordinated with officials from Hamas-controlled ministries in Gaza:

“Although several Gaza ministerial staff attend cluster meetings to share information and assist in coordinating humanitarian assistance with NGOs and UN agencies, not all information is available through the cluster system.”

Consistent with that approach, the NGO continues to demand Hamas involvement in aid distribution.

In a March 1, 2024 CBC interview, NRC’s “regional head of advocacy in the Middle East,” Samah Hadid, asserted:

“It’s absolutely crucial to have the Gazan security force in place to give them the safety they need to secure the aid convoys going in and the aid trucks going in because of the lack of security on the ground. But these police force units have said that Israel has targeted them, and they’ve been bombed… They need to be allowed to safely accompany these convoys…”

NRC and UNRWA

NRC’s relationship with UNRWA underscores how – at best – the organization is unfamiliar with its partners and their ties to terrorists.

In the 2013 joint NRC-OCHA publication, the authors praise UNRWA, presenting it as a model for how NGOs can satisfy anti-terror vetting and humanitarian concerns while operating in Gaza:

“More positively, the research team found several examples of creative reconciliation of counterterrorist and humanitarian demands, without compromising the core objectives of each. In the oPt, UNRWA has devoted considerable thought to translating counter-terrorist objectives into its own self-imposed requirement to maintain neutrality. The resulting UNRWA risk mitigation procedures, while designed to ensure that UNRWA remains neutral, also protect against diversion of UNRWA resources to terrorist groups. This is just one example of good practice on which efforts to reduce the adverse impact of counter-terrorism measures can draw.” (emphases added)

Such a position was laughable, even in 2013.  Well before the extent to which UNRWA facilities served as Hamas installations had been discovered, or before the participation of UNRWA staff in the October 7th atrocities revealed, it was common knowledge that the agency did not screen employees, partners or beneficiaries to identify membership in Hamas or other Palestinian terrorist groups.

NRC has also collaborated with UNRWA:

  • In 2021, NRC coordinated a $1.1 million cash assistance project with UNRWA and the Palestinian Ministry of Public Works and Housing (MoPWH).
  • In 2021, NRC was listed as both a coordinator and implementer of a $1.9 million project to organize summer programs for children in Gaza.  UNRWA was also listed as one of the implementing partners.

NRC and Yemen

2024 developments in Yemen highlight how NRC’s agenda is increasingly reflected in US policy.

On January 17, 2024, the State Department designated the Iranian-backed group Ansar Allah (the Houthis formal name) as a Specially Designated Global Terrorist group (SDGT).  Since October 2023, Houthi attacks on maritime shipping in the Red Sea have intensified, resulting in the deaths of sailors manning vessels traversing the area, and two US Navy Seals.

NRC condemned the 2021 US designation of the Houthis as a Foreign Terrorist Organization (FTO), lobbied for their de-designation, and denounced the 2024 decision to apply the SDGT label.

Moreover, lax US sanctions on the Houthis reflect NRC’s agenda, featuring broad exemptions for humanitarian NGOs that render these measures ineffective, allowing US-funded NGOs to fund and coordinate with the Houthis.  Notably, according to NRC-Yemen, its activities are supported by USAID’s Bureau of Humanitarian Assistance (BHA).

On February 16, 2024 the Treasury Department’s Office of Foreign Asset Control (OFAC) published a guide to the reinstituted restrictions and their impact on NGO activity.  According to the document, NGOs can make payments to Houthi officials and institutions – as well as institutions controlled by Houthi officials – as long as this is done in the ostensible context of humanitarian assistance.  According to OFAC, “These six general licenses do not authorize financial transfers to any blocked person, other than for the purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services, unless separately authorized” (emphasis added).

As the Houthis set the payment policy in the territory under their control, OFAC is essentially authorizing a “pay-to-play” paradigm, under which NGO payments to the Houthis can be labeled as “taxes” or other fees.

Additionally, the document’s FAQ section presents a number of expansive permitted scenarios:

  • NGOs can “coordinate with Ansarallah [the Houthis] regarding the transfer or distribution of humanitarian goods.”
  • “An Ansarallah member [in] a leadership role at an administrative agency or governing institution in Yemen” does not prohibit transferring funds to that agency or institution.”
  • NGOs can “fund the construction or rehabilitation of…non-commercial development projects…if they could be used by a purported or actual government institution under apparent Ansarallah control.”
  • NGOs can make “payments (e.g., cash incentives, per diems, and expenses) directly to healthcare workers, teachers, and other staff who may be associated with or formally employed by purported or actual administrative agencies or governing institutions controlled by Ansarallah.”

NRC and the US: Condemnation, lobbying and funding

Condemning US anti-terror policy

As one of the most influential donor countries, and as a champion of anti-terror vetting, the US has long posed a challenge to NRC’s agenda.

The 2013 NRC-OCHA report vilifies US efforts to prevent aid diversion by terrorists.  According to the publication, “the acquiescence of a large number of NGOs to the implementation of the US vetting system in the West Bank and Gaza, which extends to the vetting of beneficiaries, is seen as having undermined legitimate opposition to this practice by more principled humanitarian actors.”

Moreover, the NRC laments the specific results that these measures have had on Palestinian civil society:

“As well as limiting consultation and co-operation with the local authorities, donor measures introduced pursuant to counter-terrorist laws have had the effect of diminishing the crucial role of Palestinian NGOs in the humanitarian system in Gaza. Palestinian NGOs objected from the start to the introduction of the US ATC [anti-terrorism certification] in funding agreements due to sensitivities over the use of the term ‘terrorism’ to characterise what many perceive as Palestinian resistance.”

Several of the Palestinian NGOs referenced by NRC in this context are themselves linked to US-designated terrorist organizations.  As part of this campaign, the Palestinian civil society umbrella organization PNGO wrote that “In the case of Palestinians, [USAID’s] anti-terrorism clause considers Palestinians who resist the Israeli occupation to be terrorists. For instance, families of martyrs who were killed by the Israeli forces and prisoners in Israeli prisons are considered terrorists,” adding that it “ignores the legal Palestinians’ right of resistance against the Israeli occupation,” a euphemism for terrorism.

Lobbying to alter US policy

NRC was instrumental in lobbying USAID in 2020 to narrow anti-terror vetting of secondary partners, as well as shortening a grantee’s “lookback” period from ten to three years – the amount of time an NGO must wait to apply for US funding after it has cooperated with a US-designated state sponsor of terrorism or foreign terrorist organization.

As NGO Monitor research has demonstrated, the removal in this context of vetting language that required US grantees to “consider all information about that individual or entity [with which it seeks to partner] of which it is aware and all public information that is reasonably available to it or of which it should be aware,” increases the threat that US taxpayer funds will be issued to organizations that incite to violence or promote antisemitism.

(For examples of support for violence by US-funded Palestinian NGOs and their officials, see NGO Monitor’s, “New State Department Grantee Supports ‘Resistance,’ Partners with Palestinian Islamic Jihad Leaders,” “USAID-funded Palestinian NGOs: Introducing Children to Convicted Terrorists,” and “USAID 2022 West Bank and Gaza Grantees Vetting Gaps Remain”)

According to the then head of NRC’s Washington D.C. office, Joel Charny, “This victory is a demonstration of how effective our community can be when we work together…The result does not solve all of our problems by any means, but it reduces the risk of USAID partners being trapped in legal minefields as they pursue their humanitarian missions.”

Circumventing US oversight

In areas where it cannot yet alter US policy, NRC works to circumvent it.  In June 2023, the organization published, “Use of Money or Value Transfer Services by Non-Governmental Organisations,” a guide to using non-traditional payment platforms in humanitarian activity.

In a section on “NGO best practice on using money or value transfer services,” NRC describes efforts to avoid American oversight and scrutiny:

“A number of NGOs have specific, well-established and rigorous risk management and compliance procedures for MVTS [money-value transfer services] use. These tend to be designed for a specific situation and based on the needs of a given country. NGOs described a number of risk mitigation strategies, including using euros rather than US dollars for transfers.” (emphasis added)

In a footnote, NRC explains that “The USA Patriot Act provides oversight to US regulators regarding all dollar transfers in obliging them to pass through US correspondent banks, which can be a source of delays and blockages.”

NRC is promoting the practice of using non-US dollar currencies, to avoid the involvement of US banks in transactions, making them subject to US anti-terror and anti-fraud laws.

USAID funding and partnership

Despite NRC’s campaigning against US anti-terror standards, USAID has become one of the NGO’s most important champions.  In an April 2023 panel discussion, Jan Egeland described NRC’s efforts to expand humanitarian access in “hard to reach areas,” noting that “the number one partner that (sic) the last few years has been the U.S. and the [USAID] Bureau of Humanitarian Assistance.”

Indeed, USAID is a crucial donor for NRC, and increasingly looks to the organization to craft best practices for humanitarian and development aid, worldwide.

USAID is funding multiple NRC projects designed to influence US and global development policy and implementation.  This includes a $1.6 million 2022-2024 grant for “Humanitarian coordination expertise,” and a $310,000 2023-2025 grant for “Building a sustainable, localized analysis structure to guide global humanitarian decision making.”

Additionally, USAID supports specific NRC projects in countries around the world, including Iraq, Somalia, South Sudan, and other conflict regions.  Since 2021, USAID has provided over $285 million to the NGO.

US adversaries

NRC encourages Russia, China, and Iran to fund humanitarian activity

In the April 2023 panel discussion, Jan Egeland described his hope that US adversaries, namely Iran, Russia, and China, would become more involved in funding and influencing humanitarian activity.

Referring to the fact that these efforts are disproportionately funded by Western governments, Egeland asserted that “it is a problem that we are totally unevenly funded.”  His proposed solution is “a big effort for all of us to try to get Iran and Russia and China and so on to try to influence.”

The desire to receive funding from these notorious human rights abusers undermines NRC’s purported advocacy for international humanitarian law, as well as its claims of political neutrality.  The notion that these regimes would fund humanitarian activity without any political aims or directives beggars belief.

NRC efforts to reduce transparency

In the context of its current operations in Gaza, in a March 4, 2024 article, the Washington Examiner reported that the NRC asserted that “the urgent humanitarian situation in Gaza precluded it [NRC] from providing information about vetting, transparency, and subcontractors’ identities.”

This is consistent with the NRC’s efforts to decrease transparency regarding humanitarian operations.  According to UK government documents obtained in the course of a freedom of information request, the UK Foreign Commonwealth and Development Office (FCDO) cited NRC efforts to reduce transparency in UN funding databases, removing the names of implementing partners:

“Since HRP [Humanitarian Response Plan] 2019, NRC successfully lobbied [the] UN Office for the Coordination of Humanitarian Affairs (OCHA) to no longer disclose the names of local organisations unless they were directly applying to the HRP.”