Executive Summary

Development and cooperation aid is seen as one of the most effective strategies for promoting democracy and fundamental rights, as well as building sustainable and inclusive societies, particularly in places where these processes are in their initial phases. To be sure, the path to building a democratic society is a political process, traversing existing ideological and social rifts, and subject to passionate debates between different political camps. 

Especially in conflict ridden areas, politicization can result in development aid lending a platform to radical voices and amplifying inflammatory, hateful narratives. Such aid is particularly susceptible to abuse by groups that promote radical political narratives.

This is even more pronounced in the Palestinian-controlled areas, including Gaza, where many of the political factions are designated as terror groups by Europe (Hamas, Islamic Jihad, Popular Front for the Liberation of Palestine [PFLP]). 

This paper provides a case study that examines the ways that political actors propagate and legitimize radicalized narratives – namely, local Palestinian civil society organizations affiliated with the PFLP terror group, which receive European and more specifically German development aid.

The PFLP is multifaceted, consisting of overlapping functions including militant operations, local partisan political activity, and international advocacy via a “human rights” NGO network. These aspects are complementary, all contributing to the broadening of the PFLP’s sphere of influence and to achieving its goals.

The overlapping character of PFLP activities was illustrated acutely when several senior NGO employees (including those in financial leadership positions) were arrested for a PFLP terror attack in 2019, in which Rina Shnerb, a 17-year-old Israeli, was murdered. A subsequent investigation run by the Israeli Ministry of Defense (MoD) concluded that six PFLP-affiliated NGOs had diverted public funds. Ultimately, all six were designated as terror entities. 

Information showing the affiliation of the senior NGO officials to the PFLP terror group was already publicly available years before the attack – convictions or jail time for terror related offenses, public endorsement and glorification of the PFLP, simultaneously holding positions at the PFLP and the NGOs in question. Despite this, development agencies in Europe did not recognize an imminent threat in engaging with these NGOs and the PFLP-affiliated officials. 

Furthermore, even after the terror attack, the local EU representative in Ramallah, Sven Kühn von Burgsdorff sent a “clarification letter regarding the EU-funded contracts” to the Palestinian NGO network, in which he wrote that “it is understood that a natural person affiliated to, sympathizing with, or supporting any of the groups or entities mentioned in the EU restrictive lists is not excluded from benefiting from EU-funded  activities, unless his/her exact name and surname (confirming his/her identity) corresponds to any of the natural persons on the EU restrictive lists.” 

In light of the NGO involvement in the lethal terror attack, this statement sparked strong protests by elected Members of the European Parliament. After months of public debate, an additional clarification statement was issued by Ursula von der Leyen, President of the European Commission, declaring that EU vetting rules “make the participation of entities, individuals or groups of individuals affiliated, linked, or supporting terrorist organizations incompatible with any EU funding.” 

The two statements made by these European Commission officials were diametrically opposed to one another, showing the challenge that the EU faces in addressing softer forms of the terror threat in the context of development aid and civil society. 

Clearly, this situation, in which development aid is provided in a context where terror organizations operate as political actors, leaves a regulatory vacuum that can enable abuse of development programs and funds by terror affiliated political actors, including diversion of public funds to terror related activities.

The existing contracts between the EU and NGO grantees, even after the 2019 terror attack, only reference the EU terror list, which includes Palestinian entities like Hamas, Islamic Jihad, and PFLP, but does not include any persons or organizations connected or identified with them. Even the Israeli government decision to designate the NGOs in question did not lead to stronger regulatory mechanisms. 

This paper argues that the nature of the relationships between civil society actors and violent extremist movements necessitates pinpoint tools for identifying potential abuse in development aid. There is a need to recalibrate the mechanisms used to strike this balance.  

The key to addressing this inherent difficulty is to develop capacity that would better identify non-traditional extremist and radicalization agents that are affiliated with designated terror groups even if they do not necessarily participate in physical violence. Such vetting should not rely solely on classified information available only to intelligence and security services, but rather should build on readily available data collection methods. 

In this respect, our research indicated that, irrespective of the Israeli decision to designate six NGOs as terror entities, the publicly available evidence of affiliation between these NGOs and the PFLP should have been sufficient to disqualify them as partners in any development project. Evidence of this affiliation, taken solely from publicly available sources, appears in Annex “The Links between the PFLP and the European Government-funded NGO Network.” 

This paper also discusses the challenge that development frameworks face of how to improve transparency and anti-terror regulations in order to counter unintentional funding of terrorist-affiliated NGOs, while at the same time not restricting the operations of genuine human rights organizations.

While the need to introduce such improvements is relevant across Europe, this paper will focus on the German context. The report offers a set of practical recommendations aimed at assisting policy makers in expanding and implementing existing anti-terror regulations, so that more robust vetting can be introduced in the context of development aid. We argue that von der Leyen’s statement, which highlighted the importance of considering whether groups and individuals are “affiliated” with the designated terror entities, best addresses the missing specificity in the EU contracts with NGOs.  


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