Aarti Thakor

Barrister, Mishcon de Reya

Aarti is a civil law barrister, accredited mediator and Partner. Until April 2024, she was the Director of Legal and Accountancy Services (Chief Legal Officer) at the Charity Commission for England and Wales, where she led the regulator’s most significant and sensitive cases, investigations, legislative changes and policy work. She is widely regarded as one of the UK’s leading charity and regulatory lawyers, with over 20 years’ specialist experience across domestic and international charity regulation, covering national, state and sector specific issues.

Aarti now leads the firm’s consultancy, investigations and regulatory review work for major international NGOs, governments, philanthropic foundations, international institutions and charities, advising on complex, high profile regulatory matters for a range of UK and global organisations.

During her tenure at the Charity Commission, Aarti oversaw all of the regulator’s most high profile, complex and sensitive national cases, regulatory strategies and risk assessments. She led major policy and legislative projects, including contributing to the development and implementation of the Charities Acts 2016 and 2022 and providing written and oral evidence to Parliamentary Committees.

She also has advised governments globally on the development and reform of NGO regulatory systems, to ensure greater transparency and accountability for the benefit of civil society. She has extensive experience in FATF Recommendation 8, AML and CTF standards, and is currently an expert legal adviser to the EU funded Global Facility on AML/CTF, supporting governments on legislative, risk and operational reforms to NGO regulation.

Contributed to

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Financial sanctions in the charities sector

Practice Notes

This Practice Note explains how the UK financial sanctions regime applies to charities and highlights the significant legal and compliance risks they may face. It outlines how sanctions exposure can arise through donors, trustees, partners, subcontractors, beneficiaries and humanitarian operations, and examines the legal and regulatory consequences of non-compliance. The Practice Note also provides practical guidance on managing these risks through sanctions screening, due diligence, ongoing monitoring, the use of OFSI licences and applicable exemptions, and effective governance and trustee oversight. In addition, it considers reporting obligations and the interaction between financial sanctions, charity law, anti-money laundering requirements and counter-terrorism legislation.Financial sanctions overviewUnder the UK sanctions framework established by the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018) financial sanctions typically prohibit making funds or economic resources available to, or for the benefit of, designated persons—individuals, entities, or groups listed by the UK government as sanctions targets. The prohibitions are broad: it is not only direct transfers that are restricted, but any dealing which makes funds or economic resources

Corporate Crime