Sending funds overseas: a practical due-diligence checklist for trustees

Faith-based charities have always looked outward — funding relief, development, education and places of worship overseas, and responding when crises hit communities they care about. In August 2026 the Charity Commission opened two inquiries touching charities that operate internationally. One is a statutory inquiry into a large British international aid charity, amid concerns about its overseas due diligence and the end use of its funds. The other is a class inquiry into a group of charities whose funds are alleged to have supported activity in Israeli settlements — settlements widely regarded as unlawful under international law — raising distinct questions of legality and sanctions. The concerns differ in kind — one about the risk of funds reaching the wrong hands, the other about the lawfulness of the activity being funded — but the lesson is the same. Opening an inquiry is a fact-finding step, not a finding of wrongdoing; together, though, they are a clear signal that the regulator expects charities sending money overseas to be able to show how they manage the risks. This applies equally to charities of every tradition; the destinations differ, the duties are the same. Here is a practical checklist. It is general information, not advice.

Why this matters — and why it isn't about mistrust

Getting money safely to where it is needed, and being able to prove you did, is simply part of a trustee's duty to protect the charity's funds and beneficiaries. It also protects three things that are hard to win back: your reputation, your banking (weak due diligence is one reason charities lose accounts — see de-risking and your bank), and your people from the risk of funds being diverted or misused. Good due diligence is stewardship, not suspicion.

The checklist

1. Know who you are dealing with

Before any money moves, verify the partner or recipient: that they legally exist, who runs them, and whether they are who they say they are. The Commission's long-standing principle is know your partner, know your beneficiaries, know your donors. Keep evidence of the checks you did.

2. Be clear what the money is for

Agree, in writing, exactly what the funds will achieve and how they will be used. Vague or open-ended transfers are the hardest to account for and the easiest to divert.

3. Screen against sanctions and proscribed organisations — and make sure the activity itself is lawful

Check recipients and partners against the UK sanctions list and the list of proscribed (banned) organisations. But look past the recipient to the activity: a charity must act within the law, including international law. Consider whether the work you are funding, or the place where it happens, could itself be unlawful or breach sanctions — for example, funding activity in occupied territory, a settlement, or a sanctioned regime. Charities are not permitted to carry out or fund unlawful activity at all — this is not a risk to be weighed and accepted, but a line trustees cannot cross, because acting lawfully is a condition of charitable status. It is not enough that a partner looks legitimate; the end use has to be lawful too. Take particular care in or near conflict zones.

4. Move money through traceable channels

Use banking channels with a clear audit trail wherever possible, and be cautious with cash. If your bank is making international transfers difficult, that is a real and growing problem — but the answer is stronger documentation, not riskier routes.

5. Put it in a written agreement

A simple grant or partnership agreement should set the conditions of the funding, what reporting you expect, and your right to ask questions or audit. This connects to assessing partnerships to protect your organisation.

6. Monitor, and get evidence back

Due diligence is not a one-off gate at the start. Ask for reports, receipts and evidence that the work happened, proportionate to the amount and the risk. Where you safely can, verify on the ground.

7. Turn up the checks for higher-risk situations

Conflict zones, sanctioned regions, areas of high corruption or weak banking all call for enhanced due diligence — more verification, smaller tranches, closer monitoring.

8. Write it all down

The single most useful thing you can do is keep a contemporaneous record — the risk assessment, the checks, the decisions and why you made them. If the Commission, your bank or a funder ever asks, that record is your protection. It is the same principle as any good governance trail.

9. Know when to report

If something goes wrong — funds misused, a partner implicated, a serious loss — you may need to make a serious incident report to the Commission. Reporting promptly and openly is far better than being found not to have. (See giving internationally under scrutiny and our overview of sending donations abroad.)

A word on balance and fairness

Scrutiny of overseas giving is not aimed at any one community — the recent inquiries touch charities associated with different faiths and different parts of the world. Trustees should resist the temptation to see this as targeting, and instead treat robust due diligence as normal, expected practice that protects the charity and the people it serves. Equally, charities are entitled to be treated fairly and proportionately by banks and regulators; strong documentation is what lets you insist on that.

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This article is general information, not advice. Sanctions, counter-terrorism and charity law in this area are detailed and change, and the right approach depends on where and how you work. Check the current position, and if you send funds overseas and want your due-diligence framework reviewed, talk to us.