Written evidence submitted by Christian Aid (AFG0018)


This evidence is submitted by Christian Aid

  1. Context:

1.1.   Afghanistan is on the brink of a humanitarian disaster and total economic collapse. Food prices are spiking, essential services, in particular health, are unable to function and the banking system is largely suspended. Half the Afghan population is in dire need of humanitarian aid. One third are already food insecure and the UN recently warned that if urgent measures are not taken to save the economy, poverty rates in the country will rise to 97% next year. Christian Aid is working tirelessly in preparing to respond on the ground, but faced with challenges such as the liquidity crisis, we are unable to operate effectively as we lack safe and sustainable payment channels needed to run critical operations across Afghanistan and are advocating to find alternative ways of addressing this issue.

1.2.   Christian Aid and its partners agree with the UN Secretary General that Afghanistan is facing a “development emergency”. The economy was already in a downward spiral due to violence, political instability and Covid-19, and climate change is triggering escalating hunger. The onset of winter could lead to catastrophic conditions. Alongside humanitarian assistance and protection, there is an urgent need to ensure critical services are maintained, especially in health. This requires a mechanism that enables a secure flow of funding.

1.3.   Christian Aid is the official relief, development, and advocacy agency of 41 sponsoring churches in Britain and Ireland. Christian Aid has worked in Afghanistan for over 30 years and is a registered charity known in the country as CAID, with our main office in Herat and a sub-office in Kabul. In recent years our work has been supported by a number of donors, including the UN, EU, and UK government. We work as in all our country programmes through local partner organisations. Through their experience and expertise our partners are able to access some of the most vulnerable communities and ensure that their voices and needs inform our programmes.

Submission Questions

  1. What should the UK's objectives be in its relationship with Afghanistan? How should these be prioritised, and what trade-offs should be made to achieve them?

1.1.   The most immediate priority for the international community must be to prevent the complete collapse of the economic and financial system in Afghanistan. The UK government has a critical role to play in brokering an urgent multilateral agreement to stabilise the Afghan economy, including identifying and funding appropriate modalities to support vital social and economic services and address the liquidity crisis. Failure to deliver this as a matter of urgency will not only severely impact the lives and livelihoods of Afghans but will have profound humanitarian and security consequences beyond Afghanistan into the wider region and beyond. We believe that there are ways to do this that need not hinge on normalisation of diplomatic relations with the Taliban, which can build on similar experiences in countries such as Yemen and South Sudan.

1.2.   Christian Aid welcomes the G20 Extraordinary Summit outcomes of 12th October 2021. The shared goals and principles outlined provide a strong foundation for engagement with the Taliban. However, with winter fast approaching, urgent action is required to ensure humanitarian assistance reaches all those in need and prevent the collapse of basic services and increased food insecurity. The government should continue to work in collaboration with aid agencies and financial institutions through the Tri-Sector Working Group to ensure that UK counterterrorism and sanctions regulations do not inadvertently hinder the delivery of humanitarian assistance. This should include supporting appropriate interim money transfer solutions, issuing official HMG guidance, and, where needed, broad licences. (see 4.7-4.11 below)

1.3.   Moreover, any additional measures the UK government (or UN Security Council) are considering, in relation to Afghanistan, should avoid undermining critical humanitarian and peacebuilding activities.

1.4.   The UK should provide resources to initiatives by the UN and others which support neighbouring countries to open their borders to civilians fleeing Afghanistan and to always ensure respect for the principle of non-refoulement.

1.5.   The UK government has worked on women’s empowerment in Afghanistan for over the past 20 years and there is a moral imperative to ensure that this work has not been in vain.

  1. How well did the UK handle the international military withdrawal from Afghanistan, including on cross-Whitehall co-ordination? How effectively did it plan and coordinate with the US, other allies and countries in the region, particularly around the evacuation of those eligible to come to the UK? How can decision making structures be improved?

2.1.   No Answer

  1. What steps is the Government taking – alone and with partners – to mitigate the impact of the Taliban takeover on UK security, with particular reference to terrorist groups such as Al-Qaeda and ISIS?

3.1.   No Answer

  1. What are the humanitarian and human rights implications of the Taliban takeover? How can the UK support those at risk – particularly women and girls – both in the immediate and longer term? What steps is the Government taking to do this?

Financial and Banking Crisis

The UK government’s priority must be to avert humanitarian disaster. Action is needed in the coming weeks, not months. We urge the UK government to act with a sense of urgency. 

4.1.   The Afghan economy has little capacity for resilience, and it is clear that the Taliban lacks the experience to effectively govern the country and due to the freezing of Afghanistan’s assets do not have the revenue to fund basic services. This is particularly acute given the country’s historic dependency on foreign assistance, accounting for 40% of GDP and over 70% of public spending prior to the Taliban takeover.

4.2.   Currently, the country faces a cash and liquidity crisis, largely as a result of international financial institutions freezing accounts. The banking system is starved of cash with heavy restrictions put in place for those trying to access their funds. Being able to finance humanitarian activities is currently incredibly challenging and to scale up operations to meet the current needs is impossible. INGOs are struggling to pay staff salaries, Afghan civil society organisations risk folding, businesses are unable to access capital, and individuals are limited to $200 per week.  If unchecked, the Afghan economy will fail with a devastating impact on the livelihoods of all Afghans - in particular women and girls.

4.3.   Whilst we understand the reluctance to engage with the Taliban, it is essential that the UK along with other international actors build on current discussions to ensure a more nuanced policy on the withholding of revenue and foreign currency, this will include working with the United States and International Financial Institutions, especially the World Bank and International Monetary Fund. It is not tenable to expect the UN to fly large amounts of cash into the country. Therefore, it is essential that an alternative mechanism is developed that enables safe, legal, and sustainable payment routes to be developed so that INGOs and Afghan national and local NGOs can start to scale up their humanitarian activities.

4.4.   One option could be to develop multi donor trust funds under UN oversight, this would provide a mechanism that enables the funding and coordination of humanitarian assistance and support to Afghan essential services. It will be important to ensure that any mechanism is open to Afghan civil society as the consequences of starving Afghan organisations of resources is that many will fail, resulting in hard earned gains in supporting the development of a dynamic civil society being lost, this will be at a time when their role will be more important than ever.

4.5.   In addition, local and national NGOs work at the frontline, within communities, and can reach those otherwise left behind or invisible- this is an opportunity to make Grand Bargain commitments on localisation a reality by ensuring pooled funds with expedited due diligence procedures to ensure funds reach those in most distress as rapidly as possible. This is in line with the UN IASC’s recently adopted policy to mainstream localisation. For this reason, also we support the G20’s commitment to help ensure that “Specific actions and funding targets in humanitarian assistance should be focused on programs in favour of women and girls in Afghanistan[1].”


4.6.   The UNSC 1988 sanctions imposed in relation to the Taliban are implemented in UK law by the Afghanistan (Sanctions) (EU Exit) Regulations 2020. There are 135 individuals and 5 entities on the sanctions list[2], and a number of these individuals have now moved into positions in the Afghan Government, including the leadership of various key government ministries. This is creating legal risks and uncertainties for delivery of aid in Afghanistan, and it is vital there are measures in place to prevent the sanctions negatively impacting humanitarian assistance.

4.7.   A key tool available in UK law to help alleviate potential negative impacts of sanctions on humanitarian assistance is the ability to issue general or specific licences on humanitarian grounds. However, we understand that it is the UK Government’s position that they are unable to issue licences on humanitarian grounds under the Afghanistan regulations, because there is no provision to do so within the UNSC 1988 sanctions regime.

4.8.   This would appear to be an excessively narrow reading of the UK Government’s ability to issue licences on humanitarian grounds, and the UK Government should urgently re-evaluate its position on this, considering: its commitment as a UN Security Council member to delivering humanitarian assistance to Afghanistan[3]; its obligations under international humanitarian law and international human rights law[4]; and the recent decision by the United States to issue broad general licences in connection with humanitarian assistance to Afghanistan[5]. It is vital that the mistakes of the past in respect of unintended humanitarian impacts of sanctions regimes on humanitarian aid are not repeated[6].

4.9.   The renewal of the 1988 sanctions regime in December also offers an opportunity for the UK Government to work with other UN Security Council members to ensure the sanctions are aligned with international humanitarian law and human rights law, and that provision for issuance of humanitarian licences is included within the UN sanctions framework.

4.10.                      The issuance of effective guidance by the UK Government is another key tool which can help alleviate potential negative impacts of the sanctions on humanitarian assistance. The UK post-Brexit sanctions framework remains relatively new, and the situation in Afghanistan is unprecedented. This carries a risk that differing interpretations (e.g., between INGOs, donors and financial institutions) of what is permissible under the UK Afghanistan regulations will emerge, creating damaging uncertainty which will negatively impact humanitarian assistance. Issuance of guidance can help resolve this. We have been informed that the Office of Financial Sanctions Implementation intends to publish guidance by the end of October 2021, and through the international development network Bond UK aid organisations have provided a written submission to OFSI, which we hope will inform the guidance. We welcome OFSI’s decision to publish guidance, however we will reserve comment on its effectiveness, and specifically whether it is likely to be supportive of humanitarian assistance, until we have had an opportunity to review it.

Women and Girls – humanitarian and human rights and peacebuilding

4.11.                      It is still too early to see how the Taliban takeover will impact in the longer term, however, there is increasing evidence from across the country of human rights abuses and attacks on minorities. We are especially concerned by the impact this is having on women and girls. It is already clear that there are far fewer women at work and in the markets, and although some NGOs have been able to restart programming with girls attending primary school, secondary and tertiary level girls and young women are currently unable to continue their education. This is not consistent with many of the reassuring messages that have been heard from the Taliban leadership in Kabul.  We call on the UK Government to use their influence and impress upon the Taliban to put into practice their messages especially on allowing women to exercise their rights to education, employment and participation in decision making.

4.12.                      We must continue to keep pressure on the Taliban and hold them accountable for their actions. We acknowledge that withholding assets, which has crippled the banking system, is the main mechanism of leverage over the Taliban, however, it is critical that this policy is reviewed against its punitive impact on civilians, and its particular effects on women, girls and minorities.

4.13.                      Humanitarian support is urgently required, in particular to vulnerable groups. Given we know that food insecurity is prevalent and impacts women and girls the harshest and fastest - targeted humanitarian access and delivery must be prioritised in negotiations with the Taliban. The UK could play a stronger advocacy role in support of the above.

4.14.                      Programmes prioritising Afghan women and girls and the need to ensure women play a central role in humanitarian programmes should be advocated for, otherwise impact will be significantly diminished, and we will reinforce their marginalisation.

Internally Displaced Persons

4.15.                      Christian Aid welcomes the recent report of the High-Level Panel on IDPs. This a massive milestone for 55 million displaced globally. This report has the potential to enhance the dignity of each person in Afghanistan, as millions tackle food insecurity, economic and political crisis. Three and a half million people displaced inside Afghanistan need to see its recommendations implemented now.

4.16.                      We urge the government to ensure:

        Ensure a high-level meeting on internal displacement takes place in the coming weeks, and includes a focus on Afghanistan, that the proposed fund for durable solutions targets IDPs and their host communities

        A UN Special Representative on Durable Solutions be appointed without delay.

  1. What does the withdrawal from Afghanistan mean for future UK foreign policy, including relations with the US, the Indo-Pacific tilt, and the strategic approach to overseas aid?

5.1.   Investing political and diplomatic capital in working with the UN, major powers and regional actors to prevent and limit conflict can play a major role in reducing the scale of humanitarian crises and in creating conditions in which development can flourish. This approach will be critical to supporting Afghanistan and its people following the military withdrawal.

5.2.   As the pen holder for the UN SC’s Women, Peace and Security agenda, the UK government has unique convening power to press for increased efforts to foster a strategic approach that fosters collective interventions to support women and girls, in Afghanistan.

  1. How does the Taliban takeover affect the role of Russia, China and other powers in the region, and how does this affect UK interests? Where do regional powers’ interests overlap with those of the UK – including on security, migration, and economic ties – and how can the UK work effectively with these states to pursue them?

6.1.   No Answer

  1. How should the UK approach any opposition or armed resistance to the Taliban?

7.1.   No Answer













26th October 2021




[1] https://reliefweb.int/sites/reliefweb.int/files/resources/ChairsSummary.pdf

[2] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/957420/afghanistan.pdf

[3] https://undocs.org/S/RES/2593(2021)

[4] https://undocs.org/S/RES/2462(2019)

[5] https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20210924

[6] https://researchbriefings.files.parliament.uk/documents/CBP-8913/CBP-8913.pdf