Ayşe Bala Akal is a Research Assistant at the Peace Research Institute Oslo (PRIO) and associate of the Norwegian Centre for Humanitarian Studies. She is involved with various humanitarian related research projects, including “Red lines and grey zones: Exploring the ethics of humanitarian negotiation” (RedLines) and “On fair terms: The ethics of peace negotiations and mediation” (FAIR).
Tacit engagement is a relatively novel conceptualisation of a phenomenon which refers to an informal, practical form of opaque engagement taking place in frontline humanitarian negotiations. This type of engagement is mainly defined by a lack of contextual information sharing that is far more compounded than the confidentiality inherent in other humanitarian negotiation practices. Tacit engagement, in addition to a lack of information sharing, is distinguished from other modalities of ad hoc or remote engagement by the lack of official monitoring and explicit guidance given from the senior levels of international humanitarian organisations. This restraint around relaying context specific information in negotiations specifically pertains to high-risk engagements, such as with sanctioned actors and sensitive compromises.
This paper examines the implications of tacit engagement through the lens of two prevalent ethical challenges faced by humanitarian practitioners: (1) risk transfer and (2) the ability to push back on unreasonable demands from interlocutors.
Maintaining humanitarian negotiations through risk transfer to local organisations and actors has emerged as one of the few, yet highly contentious, modalities of engagement in the wake of the proliferation of various post-9/11 counterterrorism and sanctions regimes. As will be explored in the following section, tacit engagement can lead to increased risk being shifted to frontline practitioners in an effort to circumvent a variety of constraints.
The second challenge, which often manifests within the context of negotiations with armed actors, is the dilemma of whether to accept conditions favouring certain groups in return for a seat at the negotiating table and operational access, potentially in contravention of humanitarian principles. This dilemma has proven to be a consistent challenge reported by various humanitarian actors who have engaged in negotiations with Al-Shabaab in Somalia and Hay’at Tahrīr al-Shām in Syria, although the issue is by no means exclusive to these conflict settings or actors. Tacit engagement appears to compound this dilemma in a variety of ways, firstly by hindering the efforts to establish best practices in the face of unreasonable demands by armed actors and secondly by constraining humanitarians’ abilities to push back on these demands due to the threat of obstruction to humanitarian operations.
This paper draws upon a scoping review of the current literature on humanitarian negotiations and survey data collected as part of the “Red lines and grey zones: Exploring the ethics of humanitarian negotiation (RedLines)” research project, to examine a number of selected causes of tacit engagement and its negative implications relating to two prevalent dilemmas faced by negotiators on the frontlines. This paper will be a further exploration of the potential draw backs of tacit engagement in humanitarian negotiations concerning the dilemmas of risk transfer to local staff and pushing back on demands by counterparts to the negotiations.
Sanctions regimes and a culture of silence
This section looks into several causes of tacit engagement, primarily from the point of counterterrorism and sanctions regimes. While this is not an exhaustive list, this part of the paper will focus on the following factors to help define the scope of the paper: reputational, legal and fiduciary risks; lack of trust among humanitarian agencies; restrictive donor contracts; and excessive self-regulation.
Silence is integral to the facilitation of humanitarian activities through tacit engagement as it enables the mitigation of risk, particularly stemming from sanctions regimes and counterterrorism frameworks. This opaqueness around the reporting of the negotiation processes and other operational activities is a tool for the prevention of potentially disastrous instances of denial of access and consequently, aid suspension. Lena Schellhammer has illustrated the dire consequences of this in her research on north-western Syria. In this case, Hay’at Tahrīr al-Shām demanded registration fees be paid for cars and drivers delivering humanitarian assistance at the Bab al-Hawa border crossing. Newspapers covering the crisis and the aid delivery reported on the “terror tax” and proclaimed, “that sending aid to Syria’s Idlib could be a ‘terror offence’”. To prevent direct and indirect support to Hay’at Tahrīr al-Shām and inadvertently violating counterterrorism legislation, the aid departments of the USA USAID and Great Britain DFID suspended their funding for three months. This came at the expense of the civilian population who ultimately relied on the cross-border aid delivery for survival. Often this lack of transparency is the only recourse for mitigating the threat of such disasters related to exposure to reputational and legal risks.
The lack of trust among humanitarian agencies, claimed to have been worsened by counterterrorism measures, is said to be one of the reasons for this unwillingness to communicate. In the Humanitarian Policy Group (HPG) Working Paper on negotiations with Al-Shabaab in Somalia, Jackson and Aynte reveal that even sometimes where senior managers of organisations were aware of the terms of agreement with Al-Shabaab, they may have been unwilling to reveal this to other humanitarian agencies. Despite the fact that any other agency present in the Al-Shabaab controlled areas probably had to submit to similar conditions, the implications of being potentially singled out – with possible “termination of funding, criminal fines or imprisonment, [and] reputational damage” – might have simply been too high to enable cooperation among agencies. Jackson and Aynte argue that greater information sharing and collaboration among aid agencies in addressing the factors that limited access, including counter-terrorism frameworks, would have been more effective than disconnected and ad hoc efforts made in circumventing restrictions. They emphasise that a significant part of this responsibility falls on leadership positions within the humanitarian community to take a principled stand on not only engagement with Al-Shabaab but also on the hurdles created by counter-terrorism restrictions.
There are a plethora of factors that lead humanitarian actors to inevitably resort to tacit engagement to engage in negotiations in high-risk contexts. International and domestic counterterrorism laws and sanctions regimes are far from being the only drivers of risk. Most actors engaged in humanitarian negotiations, as well as scholars, accept there is an inherent risk to humanitarian negotiations and humanitarian work at large. However, the post-9/11 proliferation of these restrictions have repeatedly come into the spotlight as one of the primary impediments to humanitarian negotiations.
These restrictions not only stem from legislative frameworks but also from over-reaching and restrictive donor contracts that lead humanitarian organisations, at times, to forego funding for fear of violating the counterterrorism clauses under these contracts. One example of such a restrictive clause is the standard counterterrorism clause in the Anti-Terrorism Certification concomitant to USAID grants which stipulates that the grantee has not provided material support to terrorist entities within the last 10 years. This ‘look-back period’ was reduced to three years, and it was further clarified that the grantees were only required to check US government and UN terrorist lists when screening partners, entities and other persons. This amendment has been in large part due to collective lobbying efforts by humanitarian actors who came under vexatious litigation under the US False Claims Act (FCA), 31 U.S.C. §§ 3729 – 3733. This emerging type of US domestic litigation is another potential obstruction that can have a significant impact on the ability of humanitarian organisations to engage with certain local civil society actors. Taking into account the significance of USAID funding within the sphere of international humanitarian aid donors, the weaponisation of qui tam lawsuits can have significant implications on organisations. For example, this can further contribute to a culture of excessive pre-emptive self-regulation through an overly expansive interpretation of the constraints associated with sanctions and counterterrorism laws. Research on organisational risk management has revealed that “once-bitten” organisations have proven to have difficulties in taking deliberate steps to relax their mitigation measures and their overall stance “vis-à-vis risk.” The interviews conducted under the joint 2016 risk report suggest that memorable negative events “can stick in the collective mind and raise the risk perception across the sector as a whole.”
The first part of this section touches upon the existing risk transfer paradigm in humanitarian action by bringing the phenomenon of tacit engagement into the conversation. As will be discussed, the dilemma of risk transfer does not solely stem from tacit engagement but a variety of practices within the humanitarian space. However, tacit engagement can have an explicitly intensifying effect on this already prevalent dilemma of risk transfer.
Risk transfer and tacit engagement can have several overlapping root causes and at times tacit engagement practices are framed within the literature as modalities of risk transfer.
Risk transfer to local actors is a widely recognised trend in the literature and among practitioners, as increased reliance on local humanitarian actors, whether through partnerships with local organisations or the utilisation of local staff, has become the modus operandi for negotiating operational access. The majority of the survey respondents, consisting of humanitarian practitioners with field experience from various conflict settings, reaffirmed this by identifying “exposing local actors as negotiators verses not putting them at risk”, to be the most challenging ethical dilemma faced in humanitarian negotiations.
The continuation of humanitarian activities in highly volatile environments, to an increasing extent, depends on partnerships with or the utilisation of local actors for risk mitigation. Tacit engagement is another, more extreme manifestation of this trend of “pushing negotiation responsibilities downwards.”
Often this form of engagement is the only way of continuing negotiations and gaining operational access under increased pressure to deliver. For example, this was reported in the 2011 Somalia famine, where many aid organisations were forced to scale down their presence in Al-Shabaab controlled areas for fear of inadvertently violating counterterrorism laws. In a similar vein, many INGOs in Syria reportedly resort to outsourcing negotiation activities to local implementing partners, particularly within the context of engagement with the so-called Syrian Salvation Government (SSG).
Both the key literature on risk management and humanitarian practitioners agree, there is an inherent tension between maintaining presence, and managing the security risks of staff and the organisation. While tacit engagement, within the current context of armed conflicts and heightened risk environments, appears to be the sole alternative to withdrawing from the negotiation space entirely, certain features of this type of engagement can further aggravate the risk transfer dilemma.
According to a 2013 HPG report on the paradoxes of presence, national and local humanitarian workers, who at the time represented 90% of the personnel on the field, consistently suffered significantly higher rates of security incidents and fatalities compared to their international counterparts. Indicative of this reality, the risk threshold of local actors is reportedly already higher than that of international organisations, compelling them to tolerate and willingly take on more risk compared to international humanitarian workers. One local Syrian humanitarian actor who was interviewed as part of the 2016 NGOs and Risk Global Report by USAID, InterAction and Humanitarian Outcomes stated “This is a high-risk situation of course, but we are Syrians after all, so we are very passionate about doing this work. We make it possible for INGOs to program in Syria and would be doing it even without these partnerships.” The prevailing partnering practices within the humanitarian sector, particularly within the context of negotiations with sanctioned and designated actors are structured in a manner that prevents local actors from being able to mitigate the risks arising from the greater responsibility placed on their shoulders during high-risk negotiation activities. Paradoxically, some crucial aid personnel, such as those working within the delivery chain, often face the most dire security threats, but are not even recognised as “aid workers” by the humanitarian sector`s “international elite”.
In the current climate of humanitarian action, donors increasingly favour humanitarian interventions that are “able to demonstrate value for money and tangible results.” This leads the project-based humanitarian space to be rife with donor pressure, perhaps most significantly manifested in the form of “pressure to deliver.” Bearing in mind that a handful of large international organisations dominate the humanitarian sector and receive the “lion`s share of aid resources”, in addition to the limited number of large donors within the sector, this pressure can not only perpetuate the risks that are already inherent to humanitarian negotiations but create additional risk factors. Large donors demonstrate a tendency to fund more reputed international organisations, who end up acting as intermediaries for smaller, local organisations. One suggested reason for this preference is the difficulty and relatively higher expense of administering many smaller grants. Donor pressure to “deliver tangible results” and in-group competition to partner with international humanitarian actors may lead national institutions to take further risks to be able to remain an “attractive” partner in an increasingly narrowing pool. Local organisations find it increasingly difficult to remain “eligible partners” due to excessive vetting practice under counterterrorism frameworks, and gradually bear “further risks that international aid workers would not accept.” As a result, the safety of local staff is compromised to meet the expectations of international partner organisations. In a recent Independent Commission for Aid Impact review on funding in Afghanistan, the Commission revealed that “organisations in the delivery chain have a vested interest in reporting success.” A respondent to the review stated “the more facts are spun the less they will be respected … But a movie that does not make money does not get a sequel.”
Additionally, vetting requirements imposed by donors end up functioning as a roadblock for many local actors in their efforts to partner with major international humanitarian organisations. These requirements can also increase the security risks placed on local actors. The US Government’s Partner Vetting System, for instance, requires international humanitarian actor grantees to collect and provide information on their local partners and staff. Many actors believe this can create additional risks for local actors who are already in a very precarious situation, as the collection of information that is not properly stored/protected or the perception that the collected information will be passed on to government agencies can heighten threats to security and reputation.
One of the primary outcomes of this “outsourcing” trend has been major international organisations not expanding their risk management models in a way that integrates the risks of their partner organisations, rather treating them as external or unrelated.  The failure to localise security training that is typically offered to international staff has been reported by various local humanitarian actors in the field who, ironically, bear the heaviest risk while implementing the humanitarian programs developed at the senior organisational level.
Another implication of this partnership approach is the passing of donor counterterrorism requirements to local partners in the form of “flow-down clauses” which proves to be particularly problematic in the context of inappropriate risk transfer. A 2016 Norwegian Refugee Council practical guide on cycle management and counterterrorism risks reports that international humanitarian organisations often pass on donor counterterrorism requirements to their local partners without ensuring they understand what they are signing or that they have the capacity and resources to comply with the clauses. This can lead to local partners accepting clauses that can significantly increase their own operational and reputational risks. In a bid to ensure partnership with a major international organisation, local actors might also be hesitant to express their concerns or have the leverage to negotiate the clauses of the partnership agreements.
Technology facilitated international staff removal from high-risk areas and the use of technological innovation for remote management by international organisations has also been critiqued for shifting risks to vulnerable actors rather than mitigating them, concurrently leading international humanitarian actors to grow increasingly distant from their local counterparts. Critical scholars of the “humanitarian turn to technology” often argue that this phenomenon is a symptom of the increasing risk aversity of international humanitarian organisations, and appears to dominate a large part of the international-local partnership arrangements within the humanitarian sector.
There are a multitude of reasons for the current risk averse paradigm in the humanitarian sector, with some scholars arguing that certain security and insurance actors interpolating the risk calculation and management processes has fostered a sense of uncertainty and risk which does not accurately reflect the risk on the ground. The 2013 HPG report on the paradoxes of presence argues that these actors have a vested interest in fostering anxiety and, for instance, in the case of Afghanistan, the number of international aid workers who have been in simulated carjackings, likely far outnumber those who have faced a real carjacking. Regardless of whether the perception of increased risk within the humanitarian sector is accurate or exacerbated by the involvement of private actors, this perception appears to give way to a culture of risk aversion. This forces negotiation to occur at “arms-length”, either via subcontracting and/or partnerships, albeit partnerships that are unwilling and unable to share the risk of engagement, or reliance on ad hoc efforts by local staff.
It is not the rising use of local actors or the localisation agenda as a whole creates new or amplified risks in addition to the transfer of the risk, but rather the absence of capacity building and oversight that accompanies these tacit negotiation practices. Joint security assessments for example are still reported to be a rarity, despite the majority of field staff seeing insecurity as the primary threat to humanitarian operations. The leader of a local Syrian NGO who was interviewed for the L2GP report on funding to national and local humanitarian actors in Syria has commented on the partnership dynamics by stating “In the end, Syrians are the ones who risk their lives and operate inside Syria and implement the work. We want real partnerships, and we need to complement each other rather than competing with each other.” Moreover, even within the same international humanitarian organisation, security policies largely tend to be directed at expatriates regardless of the number of national field staff reportedly being much larger.
The tacit engagement modality, particularly the lack of information sharing, context specific capacity building and communication on sensitive negotiations conducted by frontline staff can both stem from, and further intensify, this dubious risk transfer trend. The absence of direct guidance or monitoring, leaves field practitioners to make sensitive decisions and develop bottom lines in isolation. In the absence of organisational guidance, the repercussions that can arise from these sorts of engagements tend to fall on the shoulders of humanitarian practitioners.
Pushing back on demands
This section focuses on another dilemma that is significantly heightened by the practice of tacit engagement: whether to accept unreasonable demands from armed actors or pushback under the threat of being denied operational access or being entirely excluded from the negotiation table. Many of the issues that emanate from the ad hoc and silent nature of tacit engagement also hinder the ability of humanitarian actors to manoeuvre in the face of such demands levied on them, leading them to give concessions, sometimes in contravention to humanitarian principles, such as impartiality and neutrality. Thus, the following will touch upon two separate features of tacit engagement: silence and lack of cohesion pertaining to negotiation practices, particularly across humanitarian organisations.
The inevitable fragmentation caused by the unstructured manner of negotiations conducted under tacit engagement can have a particularly poignant effect on the power dynamics in humanitarian negotiations. The prevailing approach of outsourcing risk to local partners and subcontractors or the lack of oversight, monitoring and capacity building during the increased utilisation of national staff can lead to fragmented negotiation practices. This is the case not only among organisations but also among different local actors who are employed under or partnered with the same international organisation(s). This fragmentation among humanitarian actors has a number of drawbacks. One of the most challenging drawbacks is the inability of local humanitarian actors to negotiate with armed groups in a structured manner that would enable them to establish best practices and build trust. In the case of Somalia, it was reported that aid agencies who were able to remain in Al-Shabaab controlled areas, in addition to avoiding paying fees or ceding control of their programming, pursued rigorous and structured engagement with Al-Shabaab at all levels. It is likely that this structured engagement enabled these aid agencies to adhere to “red lines” by communicating consistent messages.  On the flip side, the majority of the negotiations that took place were described as bilateral with little or no information sharing on negotiation strategies among agencies working within the same areas. This lack of coordinated negotiation was leveraged by Al-Shabaab, recounted by one aid worker as “When asking for a fee, the first thing they were telling you was that all of the others were paying it.”
Additionally, many in the humanitarian sector believe that armed actors have also grown increasingly aware of certain asymmetries in negotiation practices (e.g., between humanitarian organisations and donors, and local organisations and their international partners). The diverging red-lines that humanitarian actors have also incentivises them to ‘shop around’ for more malleable negotiation partners when faced with pushbacks from certain humanitarian negotiators. Different donor conditionalities have also become another pressure point to factor in during humanitarian negotiations. In the case of Syria, it has been noted that the SSG tends to understand donor regulations and tries to use these as leverage by making differentiated demands depending on the donor`s perceived level of strictness. Further, in the cases of Somalia and Sudan, there was reportedly a high degree of knowledge exchange between the de facto authorities – and governments – of both countries on how to regulate and restrict humanitarian activities, with the latter requiring humanitarian organisations to include government officials in the recruitment process of national staff. The prevailing view within the humanitarian sector is that armed groups have become increasingly more assertive in their interactions with humanitarian actors, leading to intensified attempts to instrumentalise humanitarian activities. The lack of cohesion among humanitarian actors working within the same conflict zones and the lack of coordinated negotiation efforts can often play into the hands of armed actors who want to pressure their counterparts into difficult compromises and concessions.
A 2006 UN manual on humanitarian negotiation with armed groups noted that unstructured humanitarian negotiation efforts increase the risk of armed actors being played against each other; negotiations resulting in sub-optimal agreements; and armed groups potentially being less willing to enter into negotiations in the future. Interviews conducted under this manual with UNHCR staff who took part in humanitarian negotiations in the Bosnian War reaffirmed the detriments of lack of a common position among humanitarian agencies when dealing with the warring parties. According to the interviewees, humanitarian officials in Bosnia often undermined and contradicted each other, depending on which side of the front line they were based. The resulting inconsistency at the negotiation table was exploited by the warring parties. In Médecins Sans Frontières’ (MSF) Speaking Out case study on Srebrenica, one of the major dilemmas faced by the organisation is formulated as follows, “By agreeing to provide a minimally acceptable level of relief to a besieged population, wasn’t MSF contributing, like prison doctors, to the strategy of the besieging troops while concurrently softening their image?” Whereas MSF decided to stay on in the face of a host of issues, most significantly the demands presented to them by the Serbian military authorities, the UNHCR decided on “the suspension of all aid in regions under Serbian control; the suspension of all UNHCR operations in Sarajevo and the withdrawal of the majority of its personnel, maintaining a minimal presence in this besieged town of 380,000 inhabitants; the suspension of humanitarian convoys and airlifts to Sarajevo; and UNHCR operations in Bosnian regions maintained at a reduced level where activity is still possible.”  The UN High Commissioner at the time, Sadako Ogata, stated their humanitarian efforts had become the laughingstock of political leaders and she deeply regretted that their management had forced her to take such a decision. Distancing itself from the Commissioner`s call, MSF continued to distribute emergency aid from its logistical bases in former Yugoslavia, leaving MSF, as one field coordinator in Srebrenica put it, the “only source of care in Srebrenica.” The complexity of the negotiations, in large part due the conditions imposed by the Serbian military authorities, who demanded “the equivalent of each convoy to the Muslim population for their own community”, and the bureaucracy of the Sanctions Committee greatly hampered MSF`s work in Srebrenica, the contravening stance of the major international organisations in the area potentially aggravating power imbalances at the negotiation table.
Taking into account the heightened risk placed on local humanitarian`s shoulders and the lack of risk management support that permeates through most partnership and subcontracting agreements, expecting local actors to be able to resist stipulations from counterparts when their access, both operationally and to the negotiation space, is threatened, is quite implausible. A local aid worker who was interviewed under the Centre for Strategic and International Studies report on humanitarian operations in Syria revealed that he had been detained three times for not allowing a non-state armed group to interfere in their humanitarian operations.
The phenomenon of tacit engagement, albeit observable and anecdotally reported, is yet to be systematically examined within the current literature on humanitarian negotiations. This form of engagement, which first and foremost is characterised by silence on compromises and sensitive negotiations, has a particular utility for frontline humanitarians. In a humanitarian space marked by various restrictions, tacit engagement is often one of the only tools that allows humanitarians to remain in the field and to gain access to affected populations.
Despite its utility, tacit engagement can have severe implications and exacerbate already prevalent dilemmas in humanitarian negotiation. Two instances where these detrimental implications are explicitly apparent are the dilemmas of risk transfer and pushing back on demands.
Whilst these dilemmas placed on humanitarian staff stem from different reasons that can be circumvented through tacit engagement, this paper chose to primarily focus one of the most studied challenges within the literature: sanctions and counterterrorism regimes. Thus, there are number of pathways that can, in part, alleviate this constraint brought about by sanctions and counterterrorism frameworks, which lead humanitarian practitioners to resort to tacit engagement.
In the recent years, the UN Security Council demonstrated incremental progress towards safeguarding humanitarian action against sanctions regimes and counterterrorism frameworks. The unanimously adopted Resolution 2615 (2021), enabling the provision of humanitarian aid to Afghanistan under the Taliban sanctions regime, has been deemed within scholarly literature as “one of the most important outcomes” in terms of humanitarian action. Resolution 2615 has been pointed out as an exemplar of an effective, “unequivocal” carve-out due to a number of reasons, one in particular being the inclusion of “other activities that support basic human needs in Afghanistan” and not solely emergency humanitarian assistance. The UNSC Resolution 2664 is another major breakthrough, which creates a standing restricted humanitarian exemption to asset freezes under the UN sanctions regime. Despite its significance, the Resolution has drawn criticism for its limitations pertaining to excluding other humanitarian activities, such as demining. While still limited, this Resolution may serve to alleviate a number of factors aggravating the dilemmas explored within this paper. The exemption’s efficacy will primarily depend on how well it is implemented at the national level and reflected within the private sector. Nevertheless, without addressing additional concerns such as donor restrictions, de-risking practices by financial institutions, and dubious partnering modalities, humanitarian exemptions alone will not suffice in helping humanitarian actors tackle these dilemmas.
The author is grateful to the RedLines project leaders, Kristoffer Lidén and Kristina Roepstorff, for their support, guidance, expertise, insights and assistance throughout all aspects of developing this paper.
 A forthcoming manuscript co-authored by Kristina Roepstorff, Kristoffer Liden and Ayse Bala Akal building upon the preliminary findings under the “Red lines and grey zones: Exploring the ethics of humanitarian negotiation (RedLines)” project will embark on an in-depth theoretical exploration of the phenomenon of tacit engagement.
 Erni, F., Lacalle, E., & Dill, B. (n.d.). CCHN-HHI Middle East Think Tank on Crisis Negotiation (Frontline Negotiations, p. 56). CCHN.
 Aynte, A., & Jackson, A. (2013). Talking to the other side: Humanitarian negotiations with Al-Shabaab in Somalia. GSDRC.
 Schellhammer, L. (2021). Lessons from humanitarian access negotiations under counter-terrorism legislation in north-western Syria (p. 33). Centre for Humanitarian Action.
 The survey was created as the result of a systematic desk review of secondary sources including academic studies, policy documents and reports from international humanitarian organisations to identify the most prevalent ethical dilemmas faced by humanitarian negotiators. The literature review was further informed by extensive rounds of background consultations with humanitarian practitioners and experts, including but not limited to, online meetings and seminars. The fully anonymous survey was employed to identify and rank the main ethical challenges encountered by humanitarian practitioners (for the purposes of this paper and the aims of the wider project RedLines hosted by the Peace Research Institute Oslo) within the context of humanitarian negotiations.
 The RedLines project led by Kristoffer Liden and Kristina Roepstorff aims to map out and systematically analyse the ethical dilemmas under humanitarian negotiations.
 Schellhammer, L. (2021). Lessons from humanitarian access negotiations under counter-terrorism legislation in north-western Syria (p. 33). Centre for Humanitarian Action.
 Aynte, A., & Jackson, A. (2013). GSDRC, 10.
 Ibid., 22.
 Charity-and-Security. (2020, May 21). USAID Revises Grantee Documents Relating to Anti-Terrorism Requirements. Charity & Security Network. https://charityandsecurity.org/false-claims-act-lawsuits/usaid-revises-grantee-documents-relating-to-anti-terrorism-requirements/.
 Guinane, K. (2021). The Alarming Rise of Lawfare to Suppress Civil Society: The Case of Palestine and Israel. Charity Security Network.
 Stoddard, A., Haver, K., & Czwarno, M. (4). 9.
 Steets, J., & Sagmeister, E. (2012). Evaluation and review of humanitarian access strategies in DG ECHO funded interventions (p. 8). Global Public Policy Institute.
 Erni, F., Lacalle, E., & Dill, B. (n.d.). CCHN-HHI Middle East Think Tank on Crisis Negotiation (Frontline Negotiations, p. 60). CCHN.
 Aynte, A., & Jackson, A. (2013), 8.
 Erni, F., Lacalle, E., & Dill, B. (n.d.). CCHN-HHI Middle East Think Tank on Crisis Negotiation (Frontline Negotiations, p. 63).
 Collinson, S. (2014). Paradoxes of presence: Risk management and aid culture in challenging environments (p. 5). https://odi.org/en/publications/paradoxes-of-presence-risk-management-and-aid-culture-in-challenging-environments/.
 Stoddard, A., Haver, K., & Czwarno, M. (4). How international humanitarian actors manage uncertainty. 20.
 Fairbanks, A. (2018). Going local, going safely. Humanitarian Law & Policy. https://blogs.icrc.org/law-and-policy/2018/08/08/going-local-going-safely/.
 Collinson, S. (2014). Paradoxes of presence: Risk management and aid culture in challenging environments (p. 5). https://odi.org/en/publications/paradoxes-of-presence-risk-management-and-aid-culture-in-challenging-environments/
 Norwegian Refugee Council and Handicap International, Challenges to Principled Humanitarian Action: Perspectives from Four Countries. (Geneva: Norwegian Refugee Council and Handicap International, 2016).
 Stoddard, A. (2003). Humanitarian NGOs: Challenges and Trends (HPG Briefing, p. 1).
 Robillard, S., Jean, I., Gingerich, T., Mejía, C. E., Farfan, L. B., Grisgraber, D., Joseph, T., & Maxwell, D. (2020). Anchored in Local Reality: Case Studies on Local Humanitarian Action from Haiti, Colombia, and Iraq (p. 14). Oxfam & Feinstein International Centre.
 Hall, N., & Todman, W. (2021). Lessons Learned from a Decade of Humanitarian Operations in Syria (p. 2). CSIS.
 Collinson, S. (2014). (p. 24).
 Stoddard, A., Haver, K., & Czwarno, M. (4). 20.
 Ibid., 4.
 Hermann, E., & Oberholzer, S. (2019). Security Risk Management and Risk Aversion in the Humanitarian Sector: Assessing Decision-Making Processes in Local and International Humanitarian NGOs – World | ReliefWeb (p. 25). https://reliefweb.int/report/world/security-risk-management-and-risk-aversion-humanitarian-sector-assessing-decision.
 Norwegian Refugee Council. (2020). Project Cycle Management and Counterterrorism Risks (p. 3).
 Kalkman, J. P. (2018). Practices and consequences of using humanitarian technologies in volatile aid settings. Journal of International Humanitarian Action, 3(1), 1. https://doi.org/10.1186/s41018-018-0029-4.
 Collinson, S. (2014). Paradoxes of presence: Risk management and aid culture in challenging environments (p. 27). https://odi.org/en/publications/paradoxes-of-presence-risk-management-and-aid-culture-in-challenging-environments/.
 Ibid., 7.
 Stoddard, A., Haver, K., & Czwarno, M. (4). 4.
 Els, C., Mansour, K., & Carstensen, N. (2016). Funding to national and local humanitarian actors in Syria: Between sub-contracting and partnerships (p. 19). L2GP.
 Guidero, A. (2022). Humanitarian (in)security: Risk management in complex settings. Disasters, 46(1), 162–184. https://doi.org/10.1111/disa.12457.
 Aynte, A., & Jackson, A. (2013). GSDRC, 21.
 Ibid., 10.
 Erni, F., Lacalle, E., & Dill, B. (n.d.). (Frontline Negotiations, p. 62).
 Steets, J., & Sagmeister, E. (2012). Evaluation and review of humanitarian access strategies in DG ECHO funded interventions (p. 25).
 Norwegian Refugee Council and Handicap International, Challenges to Principled Humanitarian Action: Perspectives from Four Countries. 9.
 Hugh, G. M., & Bessler, M. (2006). Humanitarian Negotiations with Armed Groups: A Manual for Practitioners (p. 45). UN OCHA.
 Ibid., 48.
 MSF and Srebrenica 1993-2003 | MSF (p. 13). (2015). MSF. https://www.msf.org/speakingout/msf-and-srebrenica-1993-2003
 Ibid., 16.
 Ibid., 29.
 Hall, N., & Todman, W. (2021). Lessons Learned from a Decade of Humanitarian Operations in Syria (p. 3). https://www.csis.org/analysis/lessons-learned-decade-humanitarian-operations-syria.
 Sarfati, A. (2022). An Unfinished Agenda: Carving Out Space for Humanitarian Action in the UN Security Council’s Counterterrorism Resolutions and Related Sanctions (p. 11). IPI.
 Statement – UN Security Council adopts a humanitarian exemption for…. (n.d.). Norwegian People’s Aid. Retrieved July 10, 2023, from https://www.npaid.org/news/statement-un-security-council-adopts-a-humanitarian-exemption-for-un-sanctions-regimes.