The Charity Commission has published reports for two regulatory compliance cases involving individuals who were convicted of terrorism offences and whose actions were linked to charity. The reports demonstrate the risks to charities of being abused as vehicles for terrorism.
On 23 December 2016 Mr Syed Hoque and Mr Mashoud Miah were convicted of entering into a funding arrangement contrary to section 17 of the Terrorism Act 2000 (see notes to editor).
The case involving Mr Syed Hoque, a registered charity, Shade provided an open letter of accreditation to Mr Hoque as a volunteer of the charity. The trustees told the Commission that they accepted Mr Hoque’s assurances that his travel to Syria would help promote the charity. The letter was provided without any due diligence or establishing any means of controlling or monitoring his activities whilst acting on the charity’s behalf.
The Commission concluded that this was misconduct and mismanagement in the administration of the charity. It set the trustees of Shade a regulatory action plan, which required, among other things, for the trustees to carry out proper due diligence checks on all people and organisations that it funds or works with.
In another case, one of the individuals convicted, Mr Mashoud Miah was connected to an organisation raising charitable funds and which stated publicly that it was a charity, Helping Humanity (not a registered charity – see notes to editor).
During the criminal investigation, the Metropolitan Police found documents relating to the organisation in Mr Miah’s possession, including meeting minutes and correspondence, which suggested he was closely involved in the organisation’s administration.
Following the Commission’s intervention, its directors ended its activities. The Commission actively monitored the directors’ actions in properly winding it up, including closing its bank account, and taking down its website. This means that the organisation and its assets can no longer be used for any future charitable activity.
The Commission is publishing these reports to help other charities minimise the risks associated with individuals who may seek to abuse charities for terrorist purposes.
The Commission has been clear that it does not consider aid convoys an effective means of delivering humanitarian aid, and has warned charities taking part in them that they will be subject to additional regulatory scrutiny to ensure trustees comply with their legal duties and responsibilities. The convictions of these individuals highlight how such convoys are susceptible to abuse.
Notes to editor
- The ‘Helping Humanity’ referred to in this case report is not a reference to the registered charity Helping Humanity (charity number 1164722) which was registered with the Commission on 7 December 2015. It is a reference to an incorporated company which was not a registered charity and which has since dissolved.
- Section 17 of the Terrorism Act 2000 states:
“A person commits an offence if –
(a) He enters into or becomes concerned in an arrangement as a result of which money or other property is made available or is to be made available to another, and
(b) He knows or has reasonable cause to suspect that it will or may be used for the purposes of terrorism.”
- The Charity Commission is the independent regulator of charities in England and Wales. To find out more about our work, see our annual report.
- The Commission’s annual report of compliance case work, Tackling abuse and mismanagement, provides further information about the Commission’s work tackling abuse of charities for terrorist related purposes.