The draft document fleshes out proposals made earlier this year by the regulator to set up a dedicated counter-terrorism unit within a year. The unit, which will contain six specially trained staff, will monitor sub-sectors deemed to be at high risk of abuse, including undertaking site visits "where appropriate".
A spokesman said the commission was already working closely with other relevant agencies, but those relationships would be formalised in the final strategy document. He said suspicions of terrorist activity within charities would be treated as a "zero tolerance issue".
The proposals are largely in line with the joint response of the Home Office and HM Treasury to their own consultation on charities and terrorism earlier this week, which called for the commission to become more proactive in dealing with the terrorist threat (Third Sector online, 20 December).
However, the regulator's document indicates it will take a softer line than the Government with trustees who fail to prevent terrorist abuse of their charities despite their best efforts. The Government dismissed the need for a "good faith" defence to protect such trustees from prosecution, but the commission says that when trustees "act reasonably and honestly" it will "respond flexibly and will take this into account in deciding whether to take regulatory action against trustees".
Commission chief executive Andrew Hind said: "The government report makes a number of recommendations and the commission is looking at how best to take these forward. But we recognise that there's a wide range of opinion on this issue and we're keen to hear ideas and opinions from all stakeholders before our strategy is finalised."
The commission will produce guidance in the new year on its "know your beneficiary" principle and organisations' legal obligations under the Terrorism Act 2000. It will also produce the first elements of a ‘toolkit' of guidance and best practice later in the year.
The draft strategy document reads: "All parts of the UK economy, particularly the financial sector, are tightening their safeguards and strengthening their defences against terrorist abuse. As avenues for terrorists to exploit in these sectors are closed off, there is an increasing risk of attention focusing on others, including the charity sector."
But the draft document says the commission recognises that it can't eliminate all risk. "We do not have the capacity to do so. It would also place an unacceptable regulatory burden on charities and would stifle the innovation and adaptability that characterises the sector," it reads.
Comments and feedback are invited online or by post by 29 February.