A lot of things would make me nervous for this deck in this format. Your biggest benefit is that Towers doesn't see a ton of choke so you'll take many people by surprise. Still, without
A Promise or anything Smeagol is your top fighter by far and you're hoping to discard him in the Maneuver phase. Even if he takes out a big minion (which will likely have 3 vitality and avoid it), Frodo is max strength 7 and Sam is a piddly 3 without events. Site 5 against Uruks is going to be especially brutal without
Swiftly and Softly, and surviving sites 7 and 8 sounds difficult.
Honestly I'd swap this over to a Towers Standard deck so you have more to work with, but otherwise adding Pippin and Merry to discard or die when things get tough and
Hobbit Sword for Sam will go a long way. Since you're discarding Smeagol and healing Sam,
Samwise the Brave might help against Easterlings? If you keep Smeagol more often than not then I'd probably keep it as-is.
Mind Your Own Affairs and
No Use That Way will be great for putting away minions at the later sites, but still useless against Polearm....
Brace of Coneys is great, even if it does cost 1? You can always discard it if you're not gonna need it. I think
Poor Creature would be perfect for this deck: you don't have to worry about wounds if you're just gonna use
No Help For It and bring Smeagol back fully healed next turn, and you can use him to get rid of unnecessary FP cards and set up your Shadow hand a little better each turn. If
Safe Paths is just your worst way to use
You Must Help Us next turn I'd get rid of it.
For Shadow side, fully half of your cards aren't minions -- it's no wonder you can't take on big fellowships when you can't take advantage of the twilight they give. I think you're losing out by not having 4x
Uruk Hunter and at least another Ugluk (though I'd get all 4 copies myself, he's the main reason these guys are worth playing).
Uruk Foot Soldier is so situational I wouldn't keep him around at all. I'd cut down to 4-5 Skirmish events and 5-6 conditions to improve your odds of getting more than 2 minions out per site, it'd be nice to get 24 minions and 12 non-minions in the deck. I'm glad to see you include
Brought Back Alive though, such an underrated card.
I'd also make room for a copy of
Scaling Ladder to counter
Mablung, Soldier of Gondor and win an extra skirmish against Rohan. For big fellowships there is no better Uruk-hai answer than
Uruk Vanguard. You're sure to be able to afford it and you've got the battlegrounds to score 2 easy kills when he hits, plus whatever else you've got. With
Many Riddles you might want to change tactics and play those on the expendable companions instead of the fighters. At full vitality you can attempt to assign
Uruk Hunter and kill them all at once; when your opponent exerts to avoid that you can switch over to the seekers and runners who could otherwise get killed in the first skirmish anyway. I imagine you do alright against Ents though, with
Brought Back Alive? If not then
King's Room might be worthwhile to make sure those wounds go on everybody instead of mostly hobbits.