Comprehensive Counter-Terrorism

Policy updated: 10 July 2026. To be reviewed: 1 January 2027

ALRAHMAH COMMUNITY DEVELOPMENT

Counter-Terrorism, Prevention of Radicalisation, Terrorist Financing and Sanctions Compliance Policy

1. Policy Statement

Alrahmah Community Development (“Alrahmah” or “the Organisation”) is a registered charitable organisation committed to protecting the integrity of its charitable, humanitarian, educational, cultural, religious and community development activities.

Alrahmah adopts a zero-tolerance approach to terrorism, terrorist financing, unlawful extremist activity, terrorist recruitment, incitement to violence, deliberate radicalisation towards terrorism and the unlawful misuse of charitable resources.

The Organisation is committed to ensuring that its funds, premises, events, equipment, services, communication platforms and relationships with third-party organisations are not knowingly used to support, facilitate or promote terrorism.

This policy applies to all charitable work undertaken directly by Alrahmah and through collaborating organisations, whether in the United Kingdom, Sudan or other countries.

Alrahmah recognises that certain charitable programmes may operate in conflict-affected environments or support communities exposed to insecurity, displacement, poverty and humanitarian emergencies.

These circumstances require responsible risk management without compromising the Organisation’s commitment to humanity, impartiality, dignity, inclusion and the protection of vulnerable people.

Alrahmah shall neither knowingly support prohibited terrorist activities nor permit its charitable operations to be exploited for unlawful political, military, ideological or financial purposes.

This policy establishes preventive measures, safeguarding arrangements, due diligence requirements, security procedures, reporting mechanisms and emergency response responsibilities.

It complements the Organisation’s Fraud, Bribery and Corruption Prevention Policy, Whistleblowing Policy and other safeguarding and operational procedures.

2. Purpose and Objectives

The objectives of this policy are to:

Prevent Alrahmah’s activities or resources from being used to support terrorism.

Prevent terrorist financing and unlawful financial or material support.

Reduce risks of recruitment, radicalisation towards terrorism and terrorist propaganda within organisational activities.

Protect staff, volunteers, beneficiaries and members of the public.

Establish counter-terrorism security arrangements for events, community facilities and other premises.

Ensure appropriate screening and due diligence of relevant partners and suppliers.

Prevent diversion of humanitarian assistance in conflict-affected areas.

Establish proportionate procedures for responding to security threats.

Comply with applicable UK and international counter-terrorism and sanctions legislation.

Ensure third-party organisations observe equivalent protective measures.

Establish confidential reporting and incident investigation procedures.

Promote a safe, inclusive and non-discriminatory environment.

3. Scope of Application

This policy applies to all individuals and organisations acting for, representing, collaborating with or delivering funded projects on behalf of Alrahmah.

These include:

Directors and governing-body members.

Employees and temporary personnel.

Volunteers and community representatives.

Fundraising committees.

Project managers and humanitarian coordinators.

Event organisers, artists, speakers and promoters.

Contractors, suppliers and consultants.

Charitable organisations, NGOs and community associations.

International humanitarian delivery partners.

Approved subcontractors and intermediaries.

Individuals with delegated responsibility for organisational funds, facilities or equipment.

Relevant provisions also govern access to Alrahmah’s events, programmes and facilities by external users and visitors.

Alrahmah shall make appropriate contractual arrangements to ensure that collaborating organisations observe the relevant requirements of this policy.

4. Legal and Regulatory Framework

Alrahmah shall comply with legislation applicable to its activities and legal status.

Relevant UK laws include:

Terrorism Act 2000.

Anti-terrorism, Crime and Security Act 2001.

Terrorism Act 2006.

Counter-Terrorism and Security Act 2015.

Counter-Terrorism and Border Security Act 2019.

Sanctions and Anti-Money Laundering Act 2018.

Terrorism (Protection of Premises) Act 2025, when and insofar as applicable provisions are in force.

Proceeds of Crime Act 2002.

Relevant UK financial sanctions regulations.

Data Protection Act 2018 and UK GDPR.

Equality Act 2010.

Relevant health, safety and safeguarding legislation.

Alrahmah shall also consider applicable legislation in countries where it operates, while ensuring its international activities comply with UK laws that apply to the Organisation or relevant individuals.

4.1 Organisational status

Alrahmah is a registered charitable organisation and is not registered with the Charity Commission for England and Wales.

The Organisation shall not represent itself as Charity Commission-registered, and duties specific to that registration shall not automatically be assumed to apply.

However, the Organisation’s governing body remains responsible for identifying legal obligations arising from its actual legal form, activities, funding arrangements and contractual commitments.

4.2 Prevent duty

Alrahmah voluntarily adopts appropriate safeguarding measures to reduce the risk of individuals being drawn into terrorism.

The statutory Prevent duty applies to specified authorities under the Counter-Terrorism and Security Act 2015, rather than automatically to all charitable organisations.

Where Alrahmah undertakes functions subject to specific statutory requirements, the Organisation shall assess and comply with its applicable duties.

4.3 Protection of premises and public events

Alrahmah shall review the requirements of the Terrorism (Protection of Premises) Act 2025, commonly known as Martyn’s Law, when planning qualifying activities or managing premises.

The relevant statutory duties shall be implemented when legally in force and applicable to Alrahmah’s responsibilities.

Irrespective of statutory thresholds, Alrahmah shall adopt proportionate security and emergency preparedness arrangements for its public events and facilities.

5. Definitions

Terrorism: Conduct falling within the relevant statutory definitions of terrorism under applicable law.

Terrorist financing: The unlawful provision, collection, possession, use or arrangement of money or other resources for terrorist purposes.

Radicalisation towards terrorism: A process through which an individual comes to support, facilitate or participate in terrorism.

Extremism: A term that may describe harmful ideologies or conduct but does not, by itself, establish that a criminal offence has occurred. This policy focuses on unlawful activity and safeguarding risks linked to terrorism.

Proscribed organisation: An organisation prohibited under applicable UK counter-terrorism legislation.

Sanctioned person or entity: An individual or organisation subject to applicable UK sanctions restrictions.

Terrorist propaganda: Material that constitutes an offence under relevant terrorism legislation, including unlawful encouragement or dissemination.

Safeguarding concern: A concern that an individual, particularly a child or vulnerable adult, may be at risk of harm, exploitation, coercion or being drawn into terrorism.

Aid diversion: The unauthorised or unlawful redirection of humanitarian or charitable resources away from their intended purpose.

6. Governance and Responsibilities

6.1 Governing Body

The Board of Directors or Governing Body shall have overall responsibility for this policy.

Its responsibilities include:

Approving and reviewing the policy.

Assigning compliance and safeguarding responsibilities.

Reviewing organisational terrorism-related risks.

Approving high-risk programmes and partnerships.

Ensuring appropriate financial and security controls.

Reviewing serious incidents.

Authorising corrective action.

Ensuring appropriate reporting to competent authorities.

Providing adequate resources for implementation.

Obtaining professional advice where required.

6.2 Counter-Terrorism and Safeguarding Compliance Officer

The Organisation shall designate a suitably responsible officer to coordinate implementation.

The officer shall:

Maintain risk assessments.

Coordinate sanctions and partner screening.

Receive reports of terrorism-related concerns.

Liaise with appropriate safeguarding and security contacts.

Arrange relevant training.

Coordinate emergency preparedness.

Maintain confidential incident records.

Escalate serious concerns to the governing body.

Coordinate legally required external notifications.

Where feasible, separate finance, safeguarding and security leads shall be appointed. Smaller operations may combine functions where conflicts of interest are adequately managed.

6.3 Staff and volunteers

All staff and volunteers must:

Comply with this policy.

Remain alert to credible safety and safeguarding concerns.

Avoid participation in unlawful extremist or terrorist activities.

Report suspected misuse of charitable resources.

Follow event and premises security procedures.

Cooperate with lawful investigations.

Respect confidentiality and non-discrimination requirements.

6.4 Third-party organisations

Collaborating organisations shall be responsible for implementing relevant safeguards within activities under their control and complying with the terms of their agreements with Alrahmah.

7. Prevention of Radicalisation and Terrorist Recruitment

Alrahmah is committed to preventing its activities, premises and networks from being exploited to recruit individuals into terrorism or promote terrorist violence.

7.1 Prohibited activities

The following are prohibited in connection with Alrahmah’s activities:

Unlawful recruitment for terrorist organisations.

Encouragement or glorification of terrorism where prohibited by law.

Distribution of unlawful terrorist propaganda.

Fundraising for terrorist activities.

Coercing individuals to support terrorist groups.

Using charitable programmes to facilitate unlawful terrorist training or recruitment.

Deliberate targeting of vulnerable beneficiaries for terrorist exploitation.

Using organisational meetings, events or facilities to facilitate terrorism.

7.2 Safeguarding individuals at risk

Staff and volunteers should recognise that vulnerability to recruitment or exploitation may arise from a range of individual, social and environmental factors.

Possible concerns may include credible threats, coercion, attempts to recruit others for terrorist violence, or expressions of intent accompanied by other evidence suggesting a risk of harm.

Religious belief, ethnicity, nationality, cultural identity, political opinion or peaceful expression of controversial views must never be treated, on their own, as evidence of terrorism or radicalisation.

Concerns must be assessed objectively, using specific conduct and reliable information.

7.3 Referral procedures

Where credible concerns arise about an individual being drawn into terrorism:

The concern shall be recorded factually.

The designated Safeguarding Officer shall assess immediate safety risks.

Relevant information shall be shared only where lawful and necessary.

Professional safeguarding or counter-terrorism advice shall be sought where appropriate.

An appropriate referral, including to local safeguarding services or Prevent arrangements where suitable, may be made.

The individual’s dignity, privacy and legal rights shall be respected.

Personnel must not conduct unauthorised surveillance or confront potentially dangerous individuals.

8. Religious, Cultural, Educational and Community Programmes

Alrahmah shall ensure that community and religious activities are conducted lawfully and respectfully.

8.1 Speakers, teachers and programme facilitators

Before engaging an external speaker or facilitator, the Organisation shall undertake proportionate checks relevant to the role and risk.

Checks may include:

Identity verification.

Relevant professional or organisational references.

Review of publicly available material where justified.

Relevant sanctions and proscription checks.

Assessment of the proposed presentation or activity.

Disclosure of relevant conflicts of interest.

The purpose is to identify credible risks of unlawful conduct, not to restrict lawful religious expression or open discussion.

8.2 Community facilities

Facilities controlled or managed by Alrahmah must not knowingly be used for unlawful terrorist activities.

Any third party using such facilities shall be required to comply with applicable rules on public safety, lawful activities and safeguarding.

Booking arrangements should identify the responsible organiser and intended activity.

8.3 Educational and youth activities

Programmes involving children and young people must include age-appropriate safeguarding arrangements.

Staff and volunteers must not use positions of trust to promote violence, exploit participants or pressure them towards prohibited activities.

Any credible concern about terrorist recruitment or exploitation must be escalated through safeguarding procedures.

9. Digital Platforms and Online Communications

Alrahmah’s websites, social media accounts, messaging groups and other digital systems must not knowingly be used to facilitate or promote unlawful terrorist activities.

9.1 Organisational communications

Only authorised representatives may publish content on behalf of Alrahmah.

Official channels must not be used to:

Encourage or promote terrorist violence.

Disseminate unlawful terrorist propaganda.

Recruit individuals for prohibited organisations.

Raise funds for unlawful purposes.

Share sensitive information that could knowingly facilitate an attack.

Harass or intimidate individuals for reporting safeguarding concerns.

9.2 Social media moderation

Administrators shall have procedures for reviewing serious complaints, removing unlawful content where appropriate and preserving evidence when needed for a lawful investigation.

Potential criminal material shall be referred to competent authorities where required.

9.3 Cybersecurity

Appropriate security measures shall include controlled account access, multifactorauthentication where available, secure financial approvals and prompt reporting of compromised systems.

Suspected cyberattacks affecting donations, beneficiary information or operational safety must be escalated.

10. Events, Concerts and Public Gatherings

Alrahmah organises or participates in fundraising, cultural, community and educational events. Such events must incorporate proportionate counter-terrorism and public safety measures.

10.1 Event risk assessments

Before each significant event, the designated event manager shall assess:

Expected attendance.

Venue size, layout and access arrangements.

Nature of the event and any known credible threats.

Crowd movement and emergency exits.

Accessibility requirements.

Security staffing and responsibilities.

Emergency communication arrangements.

Coordination with the venue and emergency services.

Transport and arrival arrangements.

Previous relevant incidents.

10.2 Security arrangements

Depending on the nature and scale of the event, arrangements may include:

Appropriately trained security personnel.

Clear responsibilities for entrance management.

Staff awareness of suspicious behaviour and unattended items.

Appropriate access control.

Emergency evacuation and shelter procedures.

First-aid arrangements.

Safe communication with attendees.

Coordination with venue management.

Bag searches or other security measures must be lawful, proportionate, consistently applied and carried out by appropriately authorised personnel where required.

10.3 Venue and organiser responsibilities

Where an event takes place at a third-party venue, Alrahmah and the venue operator shall agree responsibilities for security and emergency planning.

Where another organisation manages an Alrahmah-supported event, contractual responsibilities must be documented.

The existence of venue security personnel does not remove Alrahmah’s responsibility to ensure its own staff and volunteers understand the agreed response arrangements.

10.4 Threatening incidents

Staff shall promptly report credible threats, threatening communications, suspicious incidents or serious breaches of security.

Where there is immediate danger, emergency services must be contacted.

Staff must not attempt to investigate or physically intervene in circumstances beyond their training or authority.

11. Emergency Preparedness and Terrorist Incident Response

Alrahmah shall maintain proportionate emergency procedures for activities, venues and facilities under its responsibility.

11.1 Emergency planning

Emergency arrangements shall address:

Serious threats of violence.

Suspected terrorist attacks.

Suspicious items or packages.

Evacuation and sheltering.

Medical emergencies.

Loss of essential communications.

Crowd safety.

Support for children and vulnerable people.

Coordination with police, emergency services and venue management.

Communication with families and stakeholders.

Each significant public event shall have a nominated Incident Lead and a designated deputy.

11.2 Immediate response to an attack

Where a serious violent attack occurs, individuals should follow police instructions and prioritise personal safety.

Public advice for a firearms or weapons attack is to Run, Hide, Tell: escape where safe, find appropriate cover if escape is not possible, and contact the police when safe to do so.

Alrahmah’s organisational emergency plan shall additionally define staff responsibilities for assessing threats, communicating warnings, supporting safe evacuation or shelter and coordinating with emergency responders.

11.3 Emergency communications

Only designated representatives may issue official statements on behalf of Alrahmah.

During an incident, personnel must not publish information that could endanger people, compromise an emergency response or disclose confidential beneficiary information.

11.4 After an incident

Following a serious incident, Alrahmah shall:

Confirm that emergency services have been contacted where necessary.

Account for affected personnel and participants where safe.

Arrange appropriate first aid and welfare support.

Preserve relevant records and evidence.

Cooperate with competent authorities.

Record the incident and immediate actions taken.

Consider necessary notifications to funders, insurers and contractual partners.

Review the effectiveness of security arrangements.

Implement corrective actions before resuming affected activities.

12. Counter-Terrorism and International Humanitarian Operations

Alrahmah recognises that its work in Sudan and other conflict-affected locations may expose personnel and charitable resources to increased security, coercion, diversion and financial compliance risks.

The Organisation shall manage these risks through documented procedures that support lawful humanitarian operations.

12.1 International project approval

Before implementing a higher-risk overseas project, Alrahmah shall document:

The intended humanitarian purpose.

Project location and security conditions.

Local implementation arrangements.

Beneficiary groups and selection procedures.

Funding and payment routes.

Relevant sanctions and counter-terrorism restrictions.

Procurement, transportation and storage arrangements.

Possible risks of coercion or diversion.

Monitoring and reporting procedures.

Emergency and contingency arrangements.

Projects involving material unresolved legal risks must not proceed without appropriate advice and governing-body authorisation.

12.2 Protection against aid diversion

Humanitarian assistance must not knowingly be redirected to unlawful military, terrorist or other prohibited purposes.

Implementing partners shall maintain reasonable controls over:

Cash and financial transfers.

Food, medicine and relief supplies.

Equipment and vehicles.

Warehousing and transportation.

Procurement and supplier payments.

Distribution and receipt of assistance.

Where conventional documentation cannot safely be obtained, alternative verification methods may be approved following documented assessment.

12.3 Coercion and unlawful demands

Personnel must report demands for unauthorised payments, seizure of supplies, forced beneficiary changes or other attempts to misuse humanitarian assistance.

Staff must not independently negotiate unlawful transfers to armed groups or other prohibited recipients.

Where immediate threats to life or safety arise, personnel must prioritise safety and report the incident as soon as practicable.

12.4 Humanitarian neutrality

Alrahmah shall not permit humanitarian assistance to be deliberately used to advance terrorist recruitment, unlawful military activity or prohibited partisan purposes.

Assistance shall be provided on the basis of genuine need and approved charitable objectives, without unlawful discrimination.

The Organisation shall not automatically exclude communities from assistance because they live in areas controlled by armed groups or other actors. The legality of the proposed assistance and applicable sanctions conditions must be assessed.

12.5 Sanctions and humanitarian exceptions

Before transferring funds or resources in circumstances involving possible restrictions, Alrahmah shall assess whether a relevant prohibition applies and whether any exception or licence is available.

The existence of a humanitarian objective does not automatically exempt a transaction from sanctions.

Where uncertainty exists, the Organisation shall obtain specialist advice and, where necessary, apply for appropriate authorisation.

13. Terrorist Financing Prevention

Alrahmah shall maintain financial controls to prevent its charitable resources from being used for unlawful purposes.

13.1 Sources of funding

Funds received through donations, sponsorship, grants, community collections and events must be appropriately recorded.

Unusual transactions shall be reviewed where warranted by their nature, source, conditions or payment arrangements.

13.2 Financial transfers

All material payments must:

Have an authorised purpose.

Be supported by appropriate documentation.

Identify the intended recipient.

Follow approved authorisation procedures.

Use lawful payment mechanisms.

Be subject to proportionate sanctions checks.

Be recorded in the Organisation’s accounting records.

13.3 Prohibited financial arrangements

Alrahmah prohibits:

Knowingly transferring resources for terrorist purposes.

Deliberately disguising prohibited recipients.

Structuring payments to avoid relevant controls.

Using false invoices or beneficiaries to conceal fund diversion.

Circumventing applicable sanctions.

Authorising unauthorised commissions or payments to prohibited groups.

Concealing credible evidence of unlawful financial activity.

13.4 Internal oversight

The designated financial officer shall regularly review relevant transactions and escalate anomalies.

Higher-risk payments may require additional authorisation and independent verification.

14. Sanctions, Proscription and Partner Screening

Alrahmah shall undertake proportionate checks on relevant third parties before commencing material activities or transferring funds.

14.1 Due diligence

Checks may include:

Identity and registration.

Governance and management.

Ownership and control.

Project history and organisational capacity.

Relevant sanctions designations.

Relevant proscription information.

Financial management arrangements.

Proposed subcontractors.

Conflicts of interest.

Known credible compliance concerns.

14.2 Screening procedures

Relevant screening shall be undertaken against current official sources, including:

The UK Sanctions List.

The Home Office list of proscribed terrorist organisations.

Other legally relevant lists or information where justified by the transaction.

Screening must not rely solely on similar names. Potential matches require appropriate identity verification and review.

14.3 Escalation of matches

Where a credible match or restriction is identified:

The affected activity shall be paused where appropriate.

No prohibited transfer shall be made.

The Compliance Officer shall be notified.

Applicable restrictions, ownership and control shall be assessed.

Relevant legal advice and reporting requirements shall be considered.

The outcome and decision shall be documented.

15. Third-Party Organisations and Collaborative Projects

This policy expressly extends to material projects undertaken with third-party organisations, regardless of whether they are registered charities, charitable organisations, NGOs, community associations, contractors or other lawful entities.

15.1 Partnership conditions

Alrahmah shall require relevant partners to:

Comply with applicable counter-terrorism and sanctions laws.

Prevent unlawful use of Alrahmah’s resources.

Maintain appropriate safeguarding and security arrangements.

Use funds only for approved charitable purposes.

Report credible terrorist financing or security concerns promptly.

Maintain verifiable financial and project records.

Permit proportionate monitoring and audit.

Prevent unlawful recruitment or propaganda within supported activities.

Obtain necessary authorisation for downstream delivery arrangements.

Cooperate with lawful investigations.

15.2 Downstream implementation

Partners must not transfer responsibility or funding to unauthorised third parties.

Where subcontracting is authorised, partners shall ensure that downstream organisations comply with appropriate contractual safeguards.

15.3 Monitoring and termination

Alrahmah may increase oversight, suspend affected payments, request an independent review or terminate contractual arrangements where material risks or breaches are identified.

Actions must be supported by contractual rights, applicable law and a proportionate assessment of beneficiary safety.

16. Threat Reporting and Escalation

All personnel must promptly report credible concerns involving terrorism, terrorist financing, unlawful recruitment, threats of violence, prohibited financial transfers or misuse of organisational facilities.

16.1 Internal reporting

Concerns shall be referred to:

The designated Counter-Terrorism and Safeguarding Compliance Officer.

The Chair of the Governing Body.

An independent governing-body member where senior personnel are implicated.

An appropriate external authority where urgent circumstances or legal obligations require direct reporting.

16.2 Reporting timeframes

16.3 Confidentiality

Reports shall be handled confidentially to the extent lawful and practicable.

Individuals raising concerns must not be subjected to retaliation.

Relevant protections within Alrahmah’s Whistleblowing Policy shall apply.

17. Investigation and External Reporting

Alrahmah shall ensure suspected breaches are assessed by appropriately independent personnel.

Where necessary, professional investigators or legal advisers may be appointed.

The Organisation shall cooperate with the police, National Crime Agency, OFSI and other competent authorities.

External reporting shall be determined by the applicable legislation and circumstances.

Where suspected financial sanctions breaches arise, Alrahmah shall assess reporting obligations and appropriate disclosure to OFSI.

Where terrorist financing offences or related suspicions arise, applicable reporting duties must be assessed without delay.

Internal investigations shall not obstruct law enforcement or prejudice evidence.

18. Non-Discrimination, Human Rights and Freedom of Expression

This policy shall be implemented fairly and consistently.

Alrahmah shall not associate terrorism risks with individuals solely because of their:

Religion or belief.

Ethnic or national origin.

Language or cultural background.

Political opinions.

Immigration or refugee status.

Association with a conflict-affected community.

Peaceful political discussion, religious expression, humanitarian advocacy and criticism of government policies shall not automatically be treated as extremist or terrorist activity.

Any safeguarding or security action must be based on credible information and relevant conduct.

Alrahmah shall respect lawful freedom of expression, freedom of religion, equality and data protection rights.

19. Training and Awareness

Alrahmah shall provide proportionate training to staff, volunteers, governing-body members and relevant project personnel.

Training may cover:

Understanding terrorism-related legal risks.

Recognising recruitment and exploitation concerns.

Safeguarding vulnerable individuals.

Sanctions screening and partner due diligence.

Suspicious financial transactions.

Venue and event safety.

Threat reporting.

Emergency preparedness.

Confidentiality and non-discrimination.

International humanitarian operations.

Personnel involved in high-risk financial or international activities may require enhanced training.

20. Compliance Monitoring and Auditing

The governing body shall oversee the effectiveness of this policy.

Monitoring shall include appropriate reviews of:

Risk assessments.

Partnership due diligence.

Financial transactions.

Event security plans.

Incident records.

Staff and volunteer training.

Corrective action.

International project oversight.

Identified weaknesses must be documented, assigned to a responsible person and reviewed until appropriately resolved.

21. Non-Compliance and Disciplinary Measures

Violations may result in proportionate measures including:

Formal warnings.

Additional training or supervision.

Suspension from organisational duties.

Termination of employment or volunteering arrangements.

Termination of third-party contracts.

Suspension of financial support.

Recovery of funds where lawfully permitted.

Referral to appropriate authorities.

All decisions shall be made fairly and consistently with applicable law.

22. Policy Review

This policy shall be reviewed annually and sooner where necessary following:

Significant changes to legislation.

Serious security incidents.

Relevant sanctions changes.

Expansion to new operating locations.

Major changes to organisational activities.

Significant audit findings.

New or increased threats to events, facilities or humanitarian operations.

The governing body shall approve material amendments.

23. Approval and Adoption

APPENDICES — IMPLEMENTATION AND COMPLIANCE

Appendix A — Counter-Terrorism Risk Assessment Matrix

Risks should be rated by likelihood and impact, with additional controls and senior approval for activities assessed as high risk.

Appendix B — Third-Party Counter-Terrorism Compliance Declaration

Appendix C — Event and Premises Safety Checklist

Event readiness 0 / 12

Official guidance and legal implementation notes

The policy incorporates current UK government guidance with several important distinctions:

Prevent: The statutory duty applies to specified authorities, not automatically to Alrahmah. Its safeguarding principles can nevertheless inform the Organisation’s voluntary procedures.

Martyn’s Law: As of October 2026, its principal protective requirements have not yet commenced. The published framework anticipates standard-tier qualifying premises with 200–799 people and enhanced-tier qualifying premises and events with 800 or more people, subject to the detailed statutory conditions and exemptions.

Emergency response: ProtectUK distinguishes personal Run, Hide, Tell guidance from the organisational incident procedures that venues should establish.

Sanctions: Sudan-related projects require transaction-specific compliance assessments. The UK Sudan sanctions regime includes defined exceptions and licensing arrangements; eligibility should not be assumed.

Reporting: Certain OFSI reporting duties apply to defined categories of relevant firms, while suspected breaches may also be voluntarily reported. Alrahmah must establish which duties apply to its circumstances.

Final adoption note: This comprehensive policy is suitable as a governing-body draft for Alrahmah’s charitable, community, humanitarian and third-party activities. Before formal approval, the Organisation should verify its exact legal constitution, assign named responsible officers, establish operational reporting arrangements and obtain appropriate legal review of international transfers and Sudan sanctions compliance.

The resulting framework addresses both financial and non-financial terrorism risks, including recruitment, safeguarding, community facilities, public events, humanitarian projects, sanctions, partnerships and emergency preparedness.

ALRAHMAH COMMUNITY DEVELOPMENT

Comprehensive Counter-Terrorism, Prevention of Radicalisation, Terrorist Financing and Sanctions Compliance Policy

Version 2.0 | October 2026 | Draft for formal approval