Editors’ Note: Samantha May discusses the “undocumented and unseen violence” that can be brought on by the regulation of Muslim charities as part of the “Financial War on Terror,” based on her 2021 book, Islamic Charity: How Charity Became Seen as a Threat to National Security (Bloombsury 2021).

The year 2026 will mark a quarter of a century since the 9/11 attacks on the United States perpetrated by al-Qaeda and the long so-called War on Terror (WoT). In many ways, we still operate in the shadow of the attack and its response: rather than the diminishing of counter-terror policies, Conor Gearty has emphasised their “rise and rise.” As we approach this dark anniversary it is worth reflecting on the impacts the WoT have had on charity and humanitarianism when specific geographies and entire peoples are becoming “unaidable.” Arguably, the crisis in humanitarianism witnessed in 2025 is the product of nearly 25 years of the over-politicisation of charity and philanthropy, combined with erroneous conflations of charity (specifically charity deemed “Muslim”) with “terrorism.”

Acting on humanitarian grounds to relieve hardships and suffering, Muslim charitable practices and pro-social behaviours facilitate the cultivation of vibrant civil societies. The global contributions of individual Muslim donors are immense, with zakat (obligatory alms) being one of the five pillars of Islam and sadaqah (voluntary alms) highly encouraged in the lived traditions of Islam. To provide an indication of the financial scale of Muslim charity, estimates claim that up to $1 trillion is collected globally annually.[1] In the UK, Muslims donate to charitable causes more than 4.3 times as much per adult than any other group by faith categorisation. The potentials of Muslim donors can be evidenced by ‘secular’ charities attempting to collect zakat (Oxfam, Save the Children, UNHCR for example). Yet, the sector has been surveyed and curtailed because of the “rise and rise” in financial counter-terror policies.

Presented by governments adopting the WoT as the “non-violent’ response,” the Financial War on Terror (FWoT) emerged in the aftermath of 9/11. The idea is that if you follow the money, you will find the criminal, and in the process curtail violence. In practice, the FWoT has resulted in disproportionate scrutiny and surveillance of Muslim-led charities, humanitarian organisations and non-profits. Rather than being non-violent, the attack on humanitarianism risks the well-being and lives of the world’s most vulnerable and increasingly of aid and humanitarian workers themselves. A Muslim charity employee, who I interviewed on the conditions of strict anonymity, stated that, “yes, people have died…but they [policy makers] don’t see the human value of their actions or the human cost of their actions.”

Rather than being non-violent, policies enacted against charities and humanitarian operations can be considered, as Rob Nixon has written, a form of “slow violence that occurs gradually and out of sight, a violence of delayed destruction that is dispersed across time and space, an attritional violence that is typically not viewed as violence at all.”

The consequences of counter-terror policies in the charitable sphere include greater suspicion directed to Muslim charities from non-Muslim populations, increased politicisation of aid/charity to specific places (e.g. Afghanistan/Palestine/Syria), disruption to charitable and aid work due to bank accounts being frozen or denied, and decreases in standards of living and/or loss of life itself when distribution of aid is restricted, delayed or denied. The consequence of such policies exposes the violence otherwise invisible in financial counter-terror strategies. The financial counter-terror system claims that if an individual and institution have nothing to hide, there is nothing to fear. Yet individuals and organisations have been embroiled in spurious allegations of terrorist financing who have no connection whatsoever to terrorism or criminal activity.

All this is despite the US government’s 9/11 Commission Report outlining that the attacks involved relatively small amounts of finance with no evidence that monies were illicit or channelled through anything other than mainstream banking institutions. The report concluded that the “origin of the funds remain unknown.” However, this same report cast suspicion on charities and humanitarian organisations by stating that “charities were a source of money and also provided significant cover, which enabled operatives to travel undetected under the guise of working for a humanitarian organisation.” This unevidenced logic took on a life of its own and has been used to justify circumvention and breaks from established humanitarian international law. The logic that “terrorists” could be using humanitarian organisations “undetected” has been extended by governments globally to justify aid sanctions on entire geographies such as Afghanistan and Syria. It is also the logic and rationale used by the current Israeli government for its targeting of hospitals, aid distribution centres and humanitarian workers in Gaza.

In October 2001, the Paris-based Financial Action Task Force adopted eight “Special Recommendations” for the global community to financially tackle “terrorism.” Non-profit voluntary organisations were singled out as “particularly vulnerable” as a sector at high risk of abuse for terrorist/extremist funding. While FATF have since amended the Special Recommendations, the damage has largely been done as policies have been enacted and expanded globally to financially monitor and trace donations and spending. Regulation and surveillance of banking, spending and especially financial transfers across state borders have now become “normal” practices.

Different countries interpreted and applied the Special Recommendations adopted by FATF in different ways. For instance, while the US initially focused on prosecution, the UK emphasised regulation via the Charity Commission of England and Wales. The US’s emphasis on prosecutions resulted in many of the largest Muslim charities in the United States being forcefully closed in the years following 9/11, including The Benevolence International Foundation, The Global Relief Foundation, and the Holy Land Foundation for Relief and Development.[2] These charitable foundations were charged with ‘Material Support’ for ‘terrorism’ under the highly controversial USA Patriot Act. Originally, ‘Material Support’ did not need to provide proof of intent of support for ‘terrorism’ (‘support’ largely includes non-violent actions such as advice or finance).[3] The global consequences have included bank closures, assets frozen, individuals arrested and charged, and the cessation of humanitarian projects.

In the context of the UK, the Charity Commission’s powers were extended to include removing trustees, freezing funds, and closing charities. The publication of the Claystone report revealed a disproportionate number of investigations on specifically Muslim-led charities in the UK. Statistics published from 2009-2018 reveal that approximately one sixth of all UK based Muslim charities have undergone some form of inquiry.[4] Since the initiation of these policies to date, despite the disproportionate investigations, no links to terrorism or political violence have been established within the UK context.

The augmentation of the powers of the Charity Commission was largely welcomed by charitable organisations in the UK. However, many of my research participants were skeptical about the increased politicisation of the regulatory body. A Muslim charity worker based in London commented in interview that the increased regulation via the Charity Commission was “quite good,” but the issue was when the powers were used “unfairly” as “then it no longer becomes… a tool for the Commission to do its job properly. It becomes someone else’s tool to further a particular narrative which, we don’t know what that is.”

Responding with resilience, the Muslim-led humanitarian and charity sector has regained some of its previous strength in the US while the UK witnessed unprecedented donations from the Covid pandemic to the present. In reaction to expanded regulations and surveillance, Muslim-led charities have sought to ensure increased accountability and transparency in their operations and communications. In many ways, as Shariq Siddiqui, Rafeel Wasif, and Micha A. Hughes have explained, Muslim-led charities based in the global north have been coerced into engaging and often mimicking “Western” charitable and humanitarian structures to be perceived as “professional.” Yet despite efforts to positively engage with emerging policies and so-called “mainstream” practices, challenges remain, particularly regarding banking, finance and aid sanctions.

In 2023, research by the Institute for Social Policy and Understanding concluded that Muslims in the United States are more likely to face banking and financing challenges than any other faith group. According to a Financial Conduct Authority report, 10% of Muslims within the UK remain unbanked. As Tom Keatinge has explained, the greatest challenges occur for organisations operating in “high risk” areas overseas. To potentially limit or prevent violent harm in the Global North, we risk introducing disproportionate harm on others who already suffer physically and economically in high-risk areas. At best, violence is thus not prevented but simply geographically relocated beyond Western audiences’ visions.

Challenges faced by banking practices have compelled charities to reassess their operational strategies in conflict zones and high-risk areas, leading some to suspend their activities in certain regions entirely. Others have chosen to work exclusively through established international organisations (such as UNRWA) to mitigate perceived risks, an approach which disciplines Muslim-led charities to act as collectors, but not distributers of funds (with serious implications for the religious obligation of zakat).

A recent report conducted by the Muslim Charity Forum in the UK highlighted some of the dangers caused by delayed transfer of funds, not only on the end receiver but also on the aid workers. The MCF report cites the following from one of their interviewees: “because of these delays, local vendors would come to our field offices demanding payment at gunpoint.” Rather than increases in security, current policies are expanding insecurities.

The efficiency and ability of charities to carry on their humanitarian work is severely hampered by intrusive documentation and restrictions on banking and financial services. In addition to the social, economic, and institutional violence occurring are the life and death consequences for end recipients of aid, especially those in “vulnerable” territories overseas. To limit or prevent violent harm in our own states, we risk inducing disproportionate harm on the already vulnerable.

The global Muslim-led charitable and humanitarian sector is thriving, dynamic and innovative. Since 9/11 the Muslim-led sector has sought to bring previously fragmented practices and institutions together to share best practice and respond to challenges. It is no coincidence, for instance, that the Muslim Charities Forum was established in 2007 as an umbrella hub for small and emerging charitable organisations. Academic journals that focus exclusively on Muslim philanthropy such as the Journal of Muslim Philanthropy and Civil Society, and the relatively recently established Muslim Humanitarian Review seek to disseminate findings and act as a bridge between scholarship and practice.

At a time when charitable donations are declining generally, and in the context of an uncertain economic outlook, there is a need to support rather than hinder, the humanitarian efforts of Muslim-led charities that seek to relieve human suffering irrespective of faith. Undermining Muslim charities simultaneously destabilises their important civil function for social cohesion, risks further alienation, marginalisation and isolation for Muslim communities and practitioners, and most importantly, ensures that entire geographies and peoples are deemed “unaidable,” resulting in undocumented and unseen violence.

-Samantha May

Samantha May is Senior Lecturer in the Department of Politics and International Relations, University of Aberdeen and author of Islamic Charity: How Charity Became Seen as a Threat to National Security (Bloombsury 2021).

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[1] Shariq Siddiqui, Rafeel Wasif, and Micha A. Hughes, Understanding Muslim Philanthropy (Edward Elgar publishing, 2024).

[2] Samantha May, Islamic Charity: How Charitable Giving Became Seen as a Threat to National Security, (London: Zed Books, 2021).

[3] Mark Sidel, “Counter-Terrorism and the Regulations of Civil Society in the USA,” Development and Change 41:2 (2010), 293-321.

[4] Atif Imtiaz, “An Examination of the Inquiries Conducted on British Muslim Charities by the Charity Commission,” The Forum (2019).