The Negative Impact of Sanctions on Humanitarian Aid

doi:10.1017/9781108915632.013

11 - The Negative Impact of Sanctions on Humanitarian Aid

from Part I - Humanitarian Consequences

Published online by Cambridge University Press: 28 November 2025

Alice Debarre

Edited by

Joy Gordon

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Joy Gordon: Affiliation:
Loyola University, Chicago

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Summary

Sanctions regimes can and have had both direct and indirect negative impacts on humanitarian action. These include restrictions on goods necessary for a humanitarian response, and de-risking by private sector actors, which restricts or prevents humanitarian organizations from accessing the services these actors provide, such as banking or transport. These challenges have been documented in humanitarian crises across the world, from Syria to Somalia, Afghanistan, and Sudan, hindering the ability of those in need to access and receive assistance and protection. There are several ways in which we can ensure sanctions regimes do not hinder aid. Chief among them is the inclusion in sanctions regimes of humanitarian exemptions, which explicitly exclude humanitarian action from their scope of application. Although progress on that front in recent years has helped, challenges remain. This chapter highlights the need for continued efforts to ensure that humanitarian action is safeguarded. These include the development of guidance on the scope of sanctions and on humanitarian exemptions, continued awareness-raising of the issue, stronger dialogue and engagement between governments, the private sector, and humanitarian organizations, and better risk sharing. Overall, there is a need to continue to put the focus on the dramatic needs of millions of people who depend on humanitarian organizations being able to do their work without hindrance and in accordance with international humanitarian law (IHL).

Keywords

de-risking humanitarian action humanitarian exemptions international humanitarian law (IHL)risk mitigation and management sanctions UN

Information

Type: Chapter
Information: Economic Sanctions from Havana to Baghdad
Legitimacy, Accountability, and Humanitarian Consequences
, pp. 212 - 237

DOI: https://doi.org/10.1017/9781108915632.013 [Opens in a new window]

Publisher: Cambridge University Press

Print publication year: 2025
Creative Commons: This content is Open Access and distributed under the terms of the Creative Commons Attribution licence CC-BY-NC 4.0 https://creativecommons.org/cclicenses/

11 The Negative Impact of Sanctions on Humanitarian Aid

Introduction

The use of sanctions as a tool towards achieving a variety of foreign policy objectives has exponentially increased in recent years. From counter-terrorism to political change and progress in the respect for human rights, states and international organizations have developed a complex web of sanctions regimes in the attempt to achieve such objectives.

As the world came to terms with the devastating impact that sanctions regimes imposed on the Former Yugoslavia, Haiti, and Iraq in the 1990s had on the civilian populations, decision-makers shifted away from comprehensive sanctions measures such as trade embargoes and tried to develop more targeted, or “smart,” sanctions. Such sanctions would, for example, target specific individuals or entities, rather than entire governments or territories, or more narrowly target certain types of goods to be embargoed, rather than entire trade sectors.

If this shift was seemingly successful in reducing the impact of sanctions on civilian populations, the scope of sanctions regimes remained in many cases too broad. These more targeted sanctions have had a number of negative consequences that were not necessarily intended when they were designed. Among these, one issue that started to be reported in the late 1990s is the negative impact that overbroad sanctions regimes have had on humanitarian action.Footnote ¹ Furthermore, we may be seeing a move back towards more comprehensive sanctions regimes, such as those imposed by the UN on the DPRK, or by the US and the EU on Syria and Russia, which consequently have more of an impact on both humanitarian actors and the civilian populations humanitarians aim to assist and protect.

The link between the implementation of sanctions and the work of humanitarian actors may not be immediately obvious, but, in fact, there are a multitude of ways in which humanitarian action can be impeded where sanctions regimes are being applied and implemented.

Humanitarian actors, guided by the principles of humanity, neutrality, independence and impartiality, work to provide protection and assistance to persons affected by armed conflict, violence, and disaster.Footnote ² These humanitarian principles have been and remain a key guiding compass for humanitarian actors today.Footnote ³ This chapter will be considering the impact of sanctions regimes on organizations conducting their activities within the framework of the humanitarian principles. Importantly, in times of armed conflict, international humanitarian law (IHL) applies and specifically protects the provision of and access to such principled humanitarian action.

Most sanctions regimes today target countries experiencing armed conflict or serious humanitarian crises, or individuals or entities based in such countries. As a result, they are implemented in contexts in which humanitarian actors operate and form part of the regulatory framework humanitarians need to navigate. Despite efforts to institute more targeted sanctions regimes, an increasing body of evidence has shown that sanctions have impacted the ability of humanitarian actors to protect and assist affected populations in accordance with IHL and the humanitarian principles.Footnote ⁴

This rather niche issue gained prominence in the context of the Covid-19 pandemic, notably following the UN Secretary-General’s public letter to the G20 countries calling for a “waiving of sanctions imposed on countries to ensure access to food, essential health supplies, and COVID-19 medical support.”Footnote ⁵ At the initial stages of the pandemic, there were concerns that humanitarian actors providing crucial responses to the Covid-19 pandemic may face sanctions-related obstacles in contexts in which they were among the few, if not the only, actors able to respond. The increased visibility of this issue also led to its politicization, with a number of sanctioned countries calling to eliminate the use of sanctions altogether, and focusing notably on their impact on humanitarian action and the humanitarian situation in sanctioned countries,Footnote ⁶ which in some ways challenged humanitarian actors’ ability to push their arguments.Footnote ⁷ Nonetheless, a number of sanctioning entities attempted to ensure their sanctions regimes did not hinder the response to the Covid-19 pandemic by accelerating the granting of humanitarian exemptions and issuing guidance containing helpful language.

As of February 2022, the armed conflict between Russia and Ukraine and the consequent imposition of massive sanctions against Russia led to further mediatization of the issue. This contributed to the fact that, in the past several years, and after many years of slow progress, significant strides have been made in ensuring that the possible negative impact sanctions regimes on humanitarian aid is limited.

This chapter will explain the various types of direct and indirect negative impacts that sanctions regimes can and have had on humanitarian action, with examples of concrete instances in which it has been impeded. It will then look at the types of solutions that are being put forward to resolve this issue and recent positive developments. It will conclude by highlighting the continued challenges in and efforts needed to ensuring the preservation of the space for principled humanitarian action.

The Direct and Indirect Impact of Sanctions on Humanitarian Action

Sanctions regimes can adversely impact humanitarian action both directly and indirectly in a number of ways.Footnote ⁸ While in some cases it is relatively easy to point to the direct causal impact a specific sanctions regime has on humanitarian activities, in most cases this is difficult. The difficulty can come from the fact that multiple sanctions regimes coexist in one context, but also from the fact that a sanctions regime may be one among many drivers of the challenges humanitarian actors face.

The different types of impact can be described as fitting into seven categories, with four direct ways in which humanitarian action can be challenged, and three indirect, but more prevalent, challenges.

The first and most direct impact would be for a humanitarian organization, or one of its staff members, to be added to a sanctions list. This would trigger sanctions measures against that individual or organization, meaning that, depending on the sanctions regime, they could be subjected to measures such as an asset freeze, or a travel ban. This seems like an unlikely possibility at the UN, where all fifteen member states of a sanctions committee would have to agree, or at the EU, where twenty-seven member states would have to unanimously agree to make such an addition to a sanctions list. However, individual states can develop their own sanctions regimes and it is not implausible that one might decide to sanction a humanitarian organization or one of its staff members. For example, in 2014, the cabinet of the United Arab Emirates (UAE) approved a list of designated terrorist organizations, which included the well-established and recognized NGO Islamic Relief UK.Footnote ⁹ This was not a sanctions regime, but does highlight the risk of such national-level decisions, as it made it a criminal offence for any individual or group to communicate with the listed entities, engage in their activities, or provide support by any means.Footnote ¹⁰ In a more recent example, Ukraine designated the Russian Red Cross under its own set of sanctions against persons contributing to the Russian aggression against Ukraine.Footnote ¹¹

The second type of impact can occur where sanctions regimes provide for a licensing or derogation (also sometimes referred to as exemptions) procedure for humanitarian activities, whereby an organization may apply for permission from the sanctioning entity to provide goods or services in an area in which sanctions apply. Such procedures are meant to ensure that humanitarian activities can go ahead in spite of the sanctions in place. However, such processes are not compliant with IHL, under which only the consent of states affected by armed conflict is relevant, whereas other states have the obligation to facilitate humanitarian assistance.Footnote ¹² These processes also restrict the right of impartial humanitarian organizations to offer services,Footnote ¹³ as they introduce a precondition that has no legal basis under IHL. Furthermore, derogations are not in line with the humanitarian principles, and can undermine the effectiveness of aid, as well as the security of humanitarian actors. Going through these procedures also requires an investment in time and resources. It can not only increase operational costs, but also create delays in the humanitarian response, thereby hampering its flexibility. Under the UN’s DPRK sanctions regime, for example, humanitarian organizations have faced challenges requesting derogations and delays in receiving them.Footnote ¹⁴ In 2018, the approval of derogations for humanitarian organizations took an average of ninety nine days, although the process later considerably improved.Footnote ¹⁵ This has made planning operations challenging, led to time running out on grants, and to eroding the trust in humanitarian actors of stakeholders on the ground.Footnote ¹⁶ In Syria, derogation processes provided for under both US and EU sanctions have also created challenges for humanitarian actors, notably adding costs not provided for in project funding and restricting the flexibility and timeliness of the humanitarian response.Footnote ¹⁷

These challenges are compounded in contexts where multiple sanctions regimes apply and where humanitarian actors have to request derogations from multiple authorities with different requirements and processes.Footnote ¹⁸ Sanctioning entities have developed guidance on derogations, which has helped clarify and streamline processes to an extent. However, this does not address the challenge inherent to such procedures, which is that they require humanitarian actors to request permission from political entities, thereby compromising their neutrality or at least the perception of their neutrality. Ultimately, the decision to grant or refuse a derogation is likely to be dictated by political and/or other non-humanitarian concerns. This could become an increasing concern if other countries start developing their own sanctions regimes with their own derogation procedures. Seeing that humanitarian actors have complied with UN, US, and EU sanctions and requested derogations, there is no reason why countries like China or Russia may not want to impose similar restrictions. This poses a very real challenge to neutral, impartial, and independent humanitarian action.

A third type of direct impact is the challenge humanitarian organizations face in importing certain types of goods necessary for their work. This is particularly the case when sanctions measures include an embargo on dual-use items, that is to say, products or technology that are primarily used for civil or commercial purposes but can also have military or weapons applications. For example, one humanitarian organization had to remove nail clippers from hundreds of hygiene kits in order for them to be allowed inside the DPRK due to the UN sanctions regime’s ban on the import of metal.Footnote ¹⁹ In Syria, humanitarian organizations have faced challenges in importing medical and other equipment, due to prohibitions on the export of dual-items in US and EU sanctions.Footnote ²⁰ Embargos defined by sanctions regimes can also have an indirect negative impact on the import of goods required for humanitarian activities, as risk-averse transit countries or suppliers can delay or block their import for fear of falling afoul of sanctions.

The fourth type of direct impact would be the prosecution of or imposition of fines on humanitarian organizations or their staff if states find them to have violated sanctions measures. This has not been a widespread issue so far, notably because it would require a proactive decision to enforce a sanctions regime against humanitarians. Humanitarians often hear from government representatives that this is not something their government would do, and some governments have even provided so-called “comfort letters” stating that a particular activity is not illegal and prosecution will not be pursued.Footnote ²¹ However, this is the exception rather than the norm. Where sanctions regimes do not have provisions that protect humanitarian organizations, this remains an extremely concerning eventuality. For example, if sanctions regimes target non-state armed groups that control territory, the provision of humanitarian assistance, such as medicine, to clinics run by those groups or their subsidiaries could be considered to be direct or indirect provision of economic resources to listed entities. This is not a theoretical problem, as it is estimated that 66 million people today are living in areas controlled by non-state armed groups.Footnote ²² Furthermore, in 2018, the Norwegian People’s Aid paid a fine of over $2 million for the organization’s interaction with US-sanctioned groups in the occupied Palestinian territory.Footnote ²³ Indeed, humanitarian organizations remain at risk of criminal prosecution under two US statutes.Footnote ²⁴ This risk came to the fore in January 2021 when the US designated the Houthis in Yemen as a Foreign Terrorist Organization, causing grave concern amongst humanitarian actors.Footnote ²⁵

Beyond what have been previously described as direct impacts, sanctions regimes can also have more indirect negative impacts on humanitarian action. These are the consequence of risk averseness by various stakeholders, notably donors and the private sector, but also humanitarian organizations, who are worried about violating sanctions regimes. This concern is exacerbated by the lack of clarity and difficulties in interpreting sanctions regulations. More generally, the difficulties humanitarian organizations encounter are also due to the complex regulatory environment, including the existence of multiple sanctions regimes, as well as other regulatory measures, notably counter-terrorism measures.

One of the main sanctions-related issues that humanitarian organizations face is de-risking by the private sector, and notably private suppliers of goods and financial institutions. These private sector actors perceive the provision of services to humanitarian actors operating in contexts where sanctions regimes apply as presenting too high of a risk of violating sanctions, and hence of exposing them to fines and potential reputational damage. This has led to restrictions on receiving and transferring humanitarian funds, the freezing or closing of accounts, or declined requests to open new accounts.Footnote ²⁶ A 2017 study showed that two-thirds of US-based nonprofit organizations working internationally experienced banking problems.Footnote ²⁷ In late 2020, a study found that those numbers remained consistent, but that the frequency with which these nonprofits experience financial access challenges nearly tripled between 2017 and 2020.Footnote ²⁸ Certain sections of the humanitarian sector are particularly at risk of financial exclusion, notably Muslim faith-based charities, and smaller, more local, organizations. For example, from January to July 2020, Islamic Relief Worldwide has reported undertaking £42 million worth of international transactions, with 43 percent of those transactions being subjected to compliance queries.Footnote ²⁹ In a particularly drastic example, the only banking channel humanitarian actors could use in the DPRK collapsed following the listing in 2017 by the US and the UN of the DPRK Foreign Trade Bank.Footnote ³⁰ This forced humanitarian organizations to rely on staff to carry large amounts of cash on their person when traveling to the country.Footnote ³¹ They also struggled to pay their national staff and maintain their structures on the ground and had to put operations on hold and even close some projects permanently.Footnote ³² In Iran, given the extensive US sanctions imposed, and despite the exemption for medicine and humanitarian goods, there were challenges in importing medicines and equipment necessary for the Covid-19 response.Footnote ³³ Humanitarian organizations have also experienced problems transferring funds into Syria.Footnote ³⁴ This has, for example, led to devising programs based on access to financial services rather than humanitarian needs. It has delayed programs to the point where they are no longer relevant, and led to debt and consequent security threats due to an inability to pay bills.Footnote ³⁵ A “Risk Management Principles Guide for Sending Humanitarian Funds into Syria and Similar High-Risk Jurisdictions” published in May 2020 gives a good sense of the complexity of the challenge.Footnote ³⁶ It is important to note here that although there are overcompliance issues from the private sector, there are also cases in which there is an objective risk of a sanctions breach, and without humanitarian exemptions in financial sanctions, a cautious approach by private suppliers in those cases is understandable.Footnote ³⁷

Another important challenge humanitarian actors face is the inclusion in donor agreements of sanctions-related clauses. Such clauses impose requirements that donors consider necessary for the work they fund to be in compliance with applicable sanctions regimes.Footnote ³⁸ Not only is complying with these requirements onerous and time-consuming for humanitarian actors,Footnote ³⁹ it also challenges their ability to be flexible, as well as to operate in a neutral and impartial manner. This is especially challenging when humanitarian actors are funded by multiple donors, which can lead to a complex web of restrictions, mandatory checks, and reporting requirements, including competing or even contradictory provisions. Of particular concern are requirements inserted in donor contracts for humanitarians to vet their beneficiaries before providing services. This is a clear red line for many organizations which aim to provide aid solely based on need.Footnote ⁴⁰ Unfortunately, like banks, some donors are increasingly risk averse, and have introduced clauses with increasingly restrictive requirements.Footnote ⁴¹ For example, for an education program for children with disabilities in Syria, one donor requested that the humanitarian organization implementing the program vet all the children’s parents.Footnote ⁴² Another organization has had to refuse funds for a Covid-19 response program in Sudan because one of the clauses in the donor contract required the organization to vet the beneficiaries of the program.Footnote ⁴³

In some cases, donors have gone so far as to pull or threaten to pull funding for programs in areas in which sanctioned entities are present.Footnote ⁴⁴ Following the blast in Beirut, for example, the US threatened to cut funding for the World Food Program if it engaged in the reconstruction of the port, as Hezbollah, a US-sanctioned entity, was likely involved in the business.Footnote ⁴⁵ WFP had to stop its reconstruction work.

These restrictions come despite the fact that humanitarian organizations have become much more professionalized in terms of due diligence and risk management procedures to ensure aid reaches people in need – an objective shared by donors and humanitarian organizations.Footnote ⁴⁶ Many humanitarian organizations have undertaken massive efforts to conduct due diligence and manage risk.Footnote ⁴⁷ In 2019, the Norwegian Refugee Council estimated that it spent over $1 million to comply with counter-terror regulations (of an approximately $540 million total budget).Footnote ⁴⁸ Some have denounced a “technocratic drift” in which the access and support to populations in need appear to be subsidiary to compliance concerns.Footnote ⁴⁹ Furthermore, what appears to often be a zero-tolerance approach is unrealistic in contexts in which humanitarian actors operate, and where there will always be residual risk of aid diversion as well as incidental benefits going to sanctioned entities. A zero-tolerance approach also makes humanitarian activities less flexible in the face of rapidly changing situations, and makes it harder for humanitarian organizations to remain neutral, impartial, and independent.

Finally, complex regulatory frameworks, of which sanctions regimes are a part, including the high risks associated with violating regulations, have an overall chilling effect on humanitarian actors. This means that humanitarians sometimes choose to err on the side of caution and self-regulate beyond what is in fact legally or contractually required.Footnote ⁵⁰ In practice, therefore, an organization may decide not to engage in a particular area, implement certain activities, or engage with certain groups for fear of falling afoul of sanctions. This has been witnessed in countries like Somalia and Afghanistan.Footnote ⁵¹ It challenges the impartiality as well as the fundamental efficacy of their activities, with the direct consequence of depriving populations in need of aid, in particular those who live in areas controlled by sanctioned entities.

How Can We Ensure Sanctions Regimes Do Not Hinder Aid?

Steps that could be taken to address the issues previously described have been put forward, notably by the humanitarian sector, for many years. Chief among these is the long-standing request by humanitarian organizations and experts for the inclusion in sanctions regimes of clauses that explicitly exclude principled humanitarian action from their scope of application. Such clauses have been described as exemptions, exceptions, or carve-outs, and are meant to ensure a safe legal space for principled humanitarian action to be conducted in accordance with IHL, without the risks related to the possible violation of sanctions measures, and without any prior approval needed from sanctioning entities. Until relatively recently, there were limited examples of such clauses being included in a UN sanctions regime, EU sanctions regimes, and national sanctions regimes such as in Canada.Footnote ⁵² However, after over a decade of advocacy, major developments took place at UN, US, EU, UK, and other levels as of 2022. A historical shift in UN sanctions policy came with the adoption in December of 2022 of UNSC Resolution 2664, which provided for a humanitarian exemption to the asset freeze measures imposed by all current and future UN sanctions regimes.Footnote ⁵³ Just a few days later, the US issued or amended its own humanitarian exemptions (or General Licenses), to apply across most of its sanctions regimes.Footnote ⁵⁴ The UK transposed Resolution 2664 into its own legal system in early 2023.Footnote ⁵⁵ In April 2022, the EU had adopted humanitarian exemptions in two of its sanctions regimes related to the conflict in Ukraine, which indicated a promising shift in its sanctions policy.Footnote ⁵⁶ In early 2023, the EU transposed UNSC Resolution 2664 in its UN-based regimes, including those to which it autonomously adds its own restrictions or listings.Footnote ⁵⁷ As of end of 2024, although no consensus had been reached on the adoption of a general humanitarian exemption across EU autonomous regimes, a case-by-case risk analysis for each regime being preferred, the EU had adopted humanitarian carve-outs in thirty-four of its forty-one sanctions regimes, including the EU framework on restrictive measures to combat terrorism.Footnote ⁵⁸

These are more than welcome developments,Footnote ⁵⁹ and the adoption of humanitarian exemptions has been shown to effectively support the delivery of aid.Footnote ⁶⁰ However, many of the challenges previously discussed will and have persisted. The effects of over two decades of sanctions policies that have negatively impacted humanitarian action cannot be reversed overnight. De-risking practices, for example, continue.Footnote ⁶¹ Furthermore, these exemptions do have limits in their scope, and their effectiveness depends on the extent of their implementation in national laws, policy, and practice.Footnote ⁶² More states and regional organizations will need to consider adopting similar humanitarian exemptions in their autonomous sanctions regimes, and preferably with harmonized language, to ensure legal predictability for humanitarian actors, the private sector, and sanctions enforcement authorities. In addition, other efforts, such as providing guidance on the scope and implementation of exemptions,Footnote ⁶³ but also due diligence and risk management measures, will continue to be necessary and are discussed further on.

Prior to the adoption of the previously mentioned landmark humanitarian exemptions, the focus had rather been on developing licenses or derogations for humanitarian actors. But rather than assuring that humanitarian action falls outside the scope of sanctions measures, they require humanitarian organizations to apply for approval from sanctioning entities for their activities. This remains an issue in some sanctions regimes, such as in the UN DPRK sanctions regime, which requires humanitarian organizations to go through an authorization process to send certain commodities into the country.Footnote ⁶⁴ As previously explained, derogations processes are far from ideal, as they are neither compliant with IHL nor in line with the humanitarian principles, and hamper the flexibility of the humanitarian response.Footnote ⁶⁵ During the Covid-19 pandemic, key sanctioning entities were keen to ensure that their derogation processes worked better. For example, the US and the UNSC DPRK Sanctions Committee accelerated the delivery of licenses for the Covid-19 response.Footnote ⁶⁶ However, this does not address the challenge to the ability of humanitarian actors to stay neutral and independent, as they are forced to seek approval for their work from political bodies. Additionally, the sanctioning entities can make constant requests for further evidence justifying the licenses before approving them.

Thus, for humanitarian organizations, derogations and licenses are not an attractive or effective solution. But even these derogations are not always available. This is sometimes due to the lack of political will on the part of sanctioning entities, and their fear of creating loopholes that would open the door to aid diversion and the misuse of the humanitarian sector by nefarious actors. Indeed, humanitarian organizations must contend with the deeply damaging narrative that humanitarian aid is at high risk of being diverted or misused and that humanitarian exemptions would lead to abuse and diversion of aid. However, although there are indeed examples of instances in which aid has been diverted or misused, there is little evidence of the supposed prevalence of the problem or of the fact that it would be exacerbated by the existence of humanitarian exemptions.Footnote ⁶⁷

At the same time, over the years, humanitarian actors have repeatedly been asked to provide evidence that the sanctions are impeding their work,Footnote ⁶⁸ and to find solutions to mitigate their impact. There is, therefore, a rather extensive body of literature that exists on the negative impact of sanctions on humanitarian action,Footnote ⁶⁹ and this despite the challenges of producing such evidence.Footnote ⁷⁰ As humanitarian actors continued to negotiate for better protections, they have faced continued requests for evidence. It forced many organizations to put resources into this and to have to strike the difficult balance between the risks they face in sharing such information with sanctioning entities and those posed by sanctions regimes which threaten the humanitarian space. For a long time, while there was some incremental progress, including a broader awareness of the challenges sanctions can create for humanitarian actors,Footnote ⁷¹ the trend seemed to rather be towards increasing restrictions on the humanitarian sector. Humanitarian organizations therefore had to engage in extremely technical discussions to try to find incremental ways of mitigating the impact of sanctions on their work. With the adoption of UNSC Resolution 2664, there has been a clear recognition of the negative impact UN sanctions can have on humanitarian action. However, states are now requesting evidence from humanitarian actors that the humanitarian exemption Resolution 2664 established is having a positive impact on their operations, hence continuing to lay the burden of proof principally on the humanitarian sector. Conversely, beyond vague fears of supposed loopholes, sanctioning entities do not tend to come forth with convincing evidence that humanitarian action should not be excluded from the scope of sanctions.Footnote ⁷²

Despite more significant progress in recent years, notably on humanitarian exemptions, risk-mitigating measures will remain necessary in order for humanitarian actors to work in areas in which sanctions apply.Footnote ⁷³ Humanitarian organizations have faced substantial risks while operating in contexts in which sanctions regimes apply. As a result, these organizations have deployed considerable investment in compliance and in setting up rigorous systems and controls. Other actors have also developed ways – albeit of varying effect – of supporting the humanitarian sector in better managing risk, such as the production by banks or governments of guidance on risk management, or the setting up by the UN of Risk Management Units.Footnote ⁷⁴ However, in particular for small or local NGOs, finding the resources to apply and implement all of this is a challenge, and donors rarely fund risk management capacity-building.Footnote ⁷⁵ Furthermore, despite these efforts, many in the sanctions, counter-terrorism, and banking spheres continue to consider the humanitarian sector as vulnerable and high risk, leading to the negative impacts previously described. This goes against the recommendation of FATF to adopt a risk-based approach with nonprofit organizations in order to not disrupt or discourage legitimate activities.Footnote ⁷⁶ In addition, the effectiveness of the sector’s systems has been recognized by the FATF, the EU, the US, and several other member states.Footnote ⁷⁷

Developing the best risk management systems, and even providing support for humanitarian organizations to do so, will not be enough to address some of the negative impacts sanctions have on humanitarian activities, and in particular those related to being able to work in a neutral, independent, and impartial manner. Risk management allows humanitarian organizations to ensure that their aid is reaching their intended beneficiaries, and that they are complying to the extent possible with the regulatory framework, including sanctions regimes. However, in some cases, this can lead to decisions to not engage in certain areas or to provide help to certain parts of the population – not because there are no humanitarian needs but because the risks of violating sanctions or other measures are too high.

What is needed is for better risk sharing among humanitarian organizations, donors, governments, and the private sector. There have been positive examples of risk sharing, such as letters from governments stating that a particular activity is not illegal and will not be prosecuted, or governments and banks coming together to set up an effective banking channel for humanitarians to use.Footnote ⁷⁸ Ensuring that donor agreements do not place the burden of complying with sanctions measures entirely on the recipient organization is another way to offload some of the risk from humanitarian organizations. Unfortunately, such approaches remain rather ad hoc, and are often the result of strong advocacy on the part of humanitarian organizations or arduous negotiation. There has been progress in the US in the last several years, with USAID sanctions-related requirements becoming less stringent,Footnote ⁷⁹ but this remains a challenge with other donors, such as some directorates of the European Commission.Footnote ⁸⁰

Better guidance on the scope of sanctions measures and therefore the risks involved can also help ensure that humanitarian organizations, donors, and the private sector do not interpret and implement them to be broader and more restrictive than they actually are. Some entities have developed guidance specifically tailored to the humanitarian sector, which helps organizations have a clearer understanding of how sanctions measures may apply or interact with their work.Footnote ⁸¹ During the Covid-19 pandemic of 2020–2023, both the US and the EU produced specific guidance, including to help ensure that available derogations were better understood and used by humanitarian actors.Footnote ⁸² Since the adoption of UNSC Resolution 2664, the UN has developed guidance on how to apply the Resolution to their respective sanctions regimes,Footnote ⁸³ and some states and the EU have adopted guidance on the humanitarian exemptions they have adopted.Footnote ⁸⁴ Although there are a number of positive examples of useful guidance being produced, there is still space for more and better guidance.Footnote ⁸⁵

Many of the negative impacts on humanitarian action stem from a lack of understanding of sanctions regimes, their scope, and how they can impact the work of humanitarian actors. There is a need to continue building awareness of the issue, and to pursue and strengthen dialogue, especially among governments, the private sector, and humanitarian organizations, in order to build much needed trust. This is an essential first step to the safeguarding of principled humanitarian activities.

Engagement already exists and has developed in the past several years at the UN and EU levels, and in some national contexts.Footnote ⁸⁶ Humanitarian actors have briefed UN sanctions committees, as well as the Council of the EU working party dealing with EU sanctions. The World Bank and the Association of Certified Anti-money Laundering Specialists have sponsored a “Stakeholder Dialogue” on de-risking.Footnote ⁸⁷ Switzerland and the European Commission have also led a dialogue on compliance with sanctions in Syria, bringing together NGOs, the financial sector, donors, and regulatory government agencies.Footnote ⁸⁸ Countries like France, the US, the UK, Kosovo, Norway, and the Netherlands have organized multi-stakeholder dialogues among the government, the private sector, and humanitarian organizations.Footnote ⁸⁹ However, such engagement among the humanitarian organizations, the sanctioning entities, and the private sectors remains somewhat limited and ad hoc. While these are positive developments in terms of creating space for dialogue and relationship-building, they are not necessarily a panacea given the extent and complexity of the issue at hand.Footnote ⁹⁰

The burden has been on the humanitarian sector to engage with what are for them nontraditional interlocutors, and, for a long time, humanitarians insufficiently engaged. This is due to a number of different reasons, including the need for resources to do so, the increased scrutiny and risk that may come with the sharing of specific information, and the difficulties of providing the requested evidence of the challenges they face.Footnote ⁹¹

There is no straightforward, bulletproof solution, as the challenges sanctions pose to humanitarian action are all heavily intertwined, and also the result of other legal and policy measures that international or regional organizations, as well as states, put in place. The impact, in particular when indirect, is very hard to roll back, and, for a long time, efforts to address these challenges, when they were deployed, were almost systematically reactive to crises and criticisms, rather than proactive. Although dynamics have shifted with the adoption of UNSC Resolution 2664, it will take time for decades of de-risking practices and the chilling effect of sanctions to be reversed.Footnote ⁹² Unfortunately, where sanctions measures hinder aid, this has an immediate impact on civilian populations in need. There is a need to proactively and preventively tackle this problem, and to more systematically and coherently implement the different avenues and means previously outlined.

Despite the various avenues for progress and some promising developments, it is clear that states are applying and will continue to apply a security-focused approach to the management of humanitarian action. It is worth noting that as security measures taken by states create increasing restrictions on the humanitarian sector, we are not necessarily seeing the same level of scrutiny for other businesses operating in these complicated contexts, including, notably, in the arms transfer business, which faces well-documented risks of diversion,Footnote ⁹³ with much more drastic consequences.Footnote ⁹⁴

Conclusion

Despite challenging dynamics, there have been some major positive developments in recent years. The adoption of a cross-cutting humanitarian exemption for financial sanctions at the UN level, followed by similar moves at US, EU, and other levels, is a game-changer.

However, humanitarian actors still face and will likely continue to face sanctions-related challenges that hinder their work. Over two decades of sanctions policy with few and inadequate safeguards for principled humanitarian aid have had a damaging effect, notably in terms of de-risking, that will be difficult to reverse and will require further action to effectively address. Furthermore, the challenges discussed in this chapter may also be caused by counter-terrorism laws and policies that are separate and distinct from sanctions, and that also require safeguards for humanitarian action. The full implementation and operationalization of recently adopted humanitarian exemptions will make an important difference. However, humanitarian actors will likely need to keep engaging in technical discussions on how to best mitigate the negative impact of sanctions regimes on their work, notably working with sanctioning entities to ensure exemptions are adopted and operationalized, and that the private sector is encouraged to be less risk averse. There is a need to continue to put the focus on the dramatic needs of millions of people who depend on humanitarian organizations being able to do their work without hindrance and in accordance with IHL.

Footnotes

¹ Claude Bruderlein, “Coping with the Humanitarian Impact of Sanctions: An OCHA Perspective,” OCHA, 1998.

² See ICRC, “The Fundamental Principles of the International Red Cross and Red Crescent Movement,” 2015.

³ However, it should be noted that the extent of their relevance, their aim, and interpretation remain the subject of constant debate and discussion. See, Hugo Slim, “You Don’t Have to Be Neutral to Be a Good Humanitarian,” The New Humanitarian, August 27, 2020, accessed November 26, 2024, www.thenewhumanitarian.org/opinion/2020/08/27/humanitarian-principles-neutrality.

⁴ See for example, InterAction, “Detrimental Impacts: How Counter-Terror Measures Impede Humanitarian Action: A Review of Available Evidence,” April 2021, accessed November 26, 2024, https://tinyurl.com/interact-detImpacts; Alice Debarre, “Making Sanctions Smarter: Safeguarding Humanitarian Action,” International Peace Institute (IPI), December 2019; Kate Mackintosh and Patrick Duplat, “Study of the Impact of Donor Counter-Terrorism Measures on Principled Humanitarian Action,” Norwegian Refugee Council, 2013; Jessica S. Burniske and Naz K. Modirzadeh, “Pilot Empirical Survey Study on the Impact of Counterterrorism Measures on Humanitarian Action,” Harvard Law School Program on International Law and Armed Conflict, March 2017; Norwegian Refugee Council, “Principles under Pressure,” 2018; Stuart Gordon and Sherine El Taraboulsi-McCarthy, “Counter-Terrorism, Bank De-risking and Humanitarian Response,” Humanitarian Policy Group of the Overseas Development Institute (ODI) Policy Brief No. 72, August 2018; Gillian McCarthy, “Survey Report: Adding to the Evidence: The Impacts of Sanctions and Restrictive Measures on Humanitarian Action,” VOICE (March 2021): 18–20.

⁵ UNSG, “Note to Correspondents: Letter from the Secretary-General to G-20 Members,” March 23, 2020. UN human rights entities made similar calls, see, OHCHR, “UN Rights Expert Urges Governments to Save Lives by Lifting All Economic Sanctions Amid COVID-19 Pandemic,” Press Release, April 3, 2020; OHCHR, “Bachelet Calls for Easing of Sanctions to Enable Medical Systems to Fight COVID-19 and Limit Global Contagion,” Press Release, March 24, 2020; OHCHR, “US Must Lift Its Cuba Embargo to Save Lives Amid COVID-19 Crisis, Say UN Experts,” Press Release, April 30, 2020; Alena Douhan, “COVID-19 Human Rights Guidance Note, COVID-19 Pandemic: Negative Impact of Unilateral Sanctions during the State of Emergency,” UN Human Rights Special Procedures, May 1, 2020.

⁶ AP News (website), “8 Countries under Unilateral Sanctions Ask UN Chief for Help,” AP News, March 26, 2020; UNGA, “Annex to Letter Dated 14 April 2020 from the Permanent Representative of Guyana to the United Nations Addressed to the Secretary-General,” A/74/803, April 14, 2020. In May 2020, the Non-aligned Movement adopted a declaration also calling for measures to eliminate the use of sanctions, see Representaciones Diplomaticas de Cuba en el Exterior, “Declaration: Online Summit-Level Meeting of the Non-aligned Movement Contact Group in Response to COVID-19,” May 4, 2020; UN Web TV (website), “Part (1/2) Virtual Arria Meeting on ‘End Unilateral Coercive Measures Now,’” November 25, 2020.

⁷ Indeed, humanitarian actors tend not to question the legitimacy of the use of sanctions as a tool to achieve certain political objectives. This would conflict with their neutrality. Rather, they aim to find ways in which the negative impact of sanctions on humanitarian action can be avoided, or at least mitigated. However, there is also the question of the more general impact sanctions can have on a humanitarian situation, which some humanitarian actors may be keen to highlight.

⁸ Alice Debarre, “Safeguarding Humanitarian Action in Sanctions Regimes,” IPI, June 2019.

⁹ The National, “List of Groups Designated Terrorist Organizations by the UAE,” November 16, 2014.

¹⁰ Gulf News, “UAE Publishes List of Terrorist Organizations,” November 15, 2014.

¹¹ Hanna Shtepa, “Ukraine Introduces Three New Sets of Sanctions against Persons Contributing to the Russian Aggression against Ukraine,” Baker Mackenzie, February 28, 2023.

¹² “Article 23,” and “Article 59” of “Geneva Convention IV: Relative to the Protection of Civilian Persons in Time of War,” August 12, 1949; “Article 70,” of “Additional Protocol I to the Geneva Conventions,” 1977; “Article 18” of “Additional Protocol II to the Geneva Conventions,” 1977; ICRC, “Rule 55,” ICRC Study on Customary International Humanitarian Law, Volume II, 2005, Chapter 17, Section C, accessed November 26, 2024, https://ihl-databases.icrc.org/en/customary-ihl/v1/rule55. For a detailed discussion on the applicability of IHL to counter-terrorism and sanctions measures, see Tristan Ferraro, “International Humanitarian Law, Principled Humanitarian Action, Counterterrorism and Sanctions: Some Perspectives on Selected Issues,” International Review of the Red Cross 103 (916–917) (February 2022): 109–155.

¹³ “Common Article 3(2), Geneva Conventions,” 1949.

¹⁴ UNSC, “Letter Dated 27 August 2019 from the Panel of Experts Established Pursuant to Resolution 1874 (2009) Addressed to the President of the Security Council,” S/2019/691, August 30, 2019; Debarre, “Making Sanctions Smarter,” 7–8.

¹⁵ Debarre, “Making Sanctions Smarter,” 7–8; UNSC, “Final Report of the Panel of Experts Submitted Pursuant to Resolution 2672,” S/2023/171, March 7, 2023: Annex 90.

¹⁶ Debarre, “Making Sanctions Smarter,” 8.

¹⁷ Debarre, “Making Sanctions Smarter,” 12; UNGA, “Report of the Special Rapporteur on the Negative Impact of Unilateral Coercive Measures on the Enjoyment of Human Rights on His Mission to the Syrian Arab Republic,” October 8, 2018; Erica Moret, “Effectiveness of Humanitarian Effectiveness to Sanctions: Lessons from the Syria Earthquake,” Carter Center, July 11, 2023: 14–16.

¹⁸ Furthermore, at the EU level, humanitarian organizations had to obtain a derogation from the “national competent authority” with whom they have the “closest link,” which is sometimes difficult to determine, and means that humanitarian organizations must sometimes file parallel applications in different EU member states, who each have different requirements and processes in place. See, for example, McCarthy, “Survey Report,” 18–20.

¹⁹ Debarre, “Safeguarding Humanitarian Action in Sanctions Regimes,” 4.

²⁰ Debarre, “Making Sanctions Smarter,” 11; Erica Moret, “Effectiveness of Humanitarian Exceptions to Sanctions: Lessons from the Syria Earthquake,” Carter Center, December 12, 2023, 16.

²¹ Moret, “Effectiveness,” 32.

²² ICRC, “Communities Facing Conflict, Climate Change and Environmental Degradation Walk a Tightrope of Survival,” Statement, September 17, 2020.

²³ Charity and Security Network (website), “Norwegian People’s Aid Settles Enforcement Case over Democracy Building and Mine Removal Projects US Says Were Material Support,” Charity and Security Network, April 18, 2018, accessed November 26, 2024, https://charityandsecurity.org/news/news_npa-_us_settle_case/.

²⁴ Antiterrorism and Effective Death Penalty Act, Pub. L. No. 104–132 (1996); and International Emergency Economic Powers Act (IEEPA), Pub. L. No. 95–223 (1977).

²⁵ See, Action Against Hunger, “Yemen: Designation ‘Houthis’ a Terrorist Organization Will Have Disastrous Impact on Civilians,” Press Release, January 12, 2021; Annie Slemrod and Ben Parker, “US ‘Terror’ Label on Yemen’s Houthis Could Hit Peace Talks, Aid,” The New Humanitarian, January 11, 2021.

²⁶ Tom Keatinge and Florence Keen, “Humanitarian Action and Non-state Armed Groups: The Impact of Banking Restrictions on UK NGOs,” Research Papers (London: Chatham House, Royal Institute of International Affairs, April 2017); Tom Keatinge, “Uncharitable Behavior,” Demos, December 2014: 54; McCarthy, “Survey Report,” 8–11.

²⁷ Note the definition of nonprofit organizations in this study goes beyond the strictly humanitarian sector. Sue Eckert, Kay Guinane, and Andrea Hall, “Financial Access for US Nonprofits,” Charity and Security Network, February 2017, accessed November 26, 2024, www.charityandsecurity.org/system/files/FinancialAccessFullReport_2.21%20(2).pdf

²⁸ Steven Orientale, “The Impacts of Sanctions on Humanitarian Assistance: Bringing Data into the Conversation,” Yale Jackson School of Global Affairs, September 1, 2021.

²⁹ Khaleel Desai, “ICVA Webinar: The Impact of Derisking Humanitarian Action,” Islamic Relief Worldwide, October 22, 2020.

³⁰ UNSC, “Resolution 2371 (2017),” S/RES/2371, August 5, 2017; U.S. Department of the Treasury, “Treasury Sanctions Banks and Representatives Linked to North Korean Financial Networks,” September 26, 2017. This was despite the UN sanctions regime’s exception for financial transactions made solely for humanitarian assistance activities. This remains an issue today. The lack of a banking channel enabling humanitarian operations is one of the main challenges identified. See UNSC, “Final Report of the Panel of Experts,” S/2023/171, March 7, 2023: 79.

³¹ UNSC, “Final Report of the Panel of Experts of the 1718 DPRK Sanctions Committee,” S/2019/171, March 5, 2019: Annex 85.

³² Debarre, “Making Sanctions Smarter,” 7.

³³ See, Associated Press, “Iran says US Sanctions Hinder Access to COVID-19 Vaccines,” December 9, 2020; France 24, “COVID-19 et sanctions américaines, la double peine des Iraniens,” December 4, 2020.

³⁴ UNGA, “Report of the Special Rapporteur,” 8–9. This is mainly as a consequence of broad US and EU financial sanctions against Syrian individuals and entities supporting the regime, including banks, but UN and other counter-terrorism sanctions against IS and al-Qaida add another layer of complexity, further increasing the risk for banks. See also Moret, “Effectiveness,” 3, 13; Gabija Leclerc, “Impact of Sanctions on the Humanitarian Situation in Syria, Briefing,” European Parliamentary Research Service, June 2023, 7.

³⁵ Keatinge and Keen, “Humanitarian Action,” 3; Stuart Gordon et al., “The Impact of Bank De-risking on the Humanitarian Response to the Syrian Crisis,” Humanitarian Policy Group of ODI, August 2018; Gordon and Taraboulsi-McCarthy, “Counter-Terrorism,” 2; Debarre, “Making Sanctions Smarter,” 10.

³⁶ Justine Walker, “Risk Management Principles Guide for Sending Humanitarian Funds into Syria and Similar High-Risk Jurisdictions,” Geneva Graduate Institute, May 2020.

³⁷ Interview, humanitarian expert, July 2023.

³⁸ See, for example, a clause in EU contracts requiring that: “Grant beneficiaries and contractors must ensure that there is no detection of subcontractors, natural persons, including participants to workshops and/or trainings and recipients of financial support to third parties, in the list of EU restrictive measures,” in European Commission, “Procurement and Grants for European Union External Actions: A Practical Guide,” July 15, 2019.

³⁹ See, McCarthy, “Survey Report,” 15–16.

⁴⁰ See, for example, Pierre Micheletti, “Nous, humanitaires, ne choisissons pas entre les bons et les mauvais malades, entre les bons ou les mauvais blesses,” Le Monde, December 22, 2020.

⁴¹ See, for example, Counterterrorism and Humanitarian Engagement Project, “An Analysis of Contemporary Counterterrorism-Related Clauses in Humanitarian Grant and Partnership Agreement Contracts,” May 2014. The introduction of humanitarian exemptions has facilitated the negotiation of principled contractual agreements with certain donors in certain contexts. However, other donors, such as the European Commission (outside of DG ECHO), has developed a more restrictive template clause, which requires compliance with EU sanctions “down to the level of final beneficiaries.” See, European Commission, “ePRAG, Basic Rules, 2.4 EU Restrictive Measures,” January 20, 2025, accessed June 22, 2025, https://tinyurl.com/eu-rules-sanctions.

⁴² Interview, humanitarian expert, November 2020.

⁴³ Interview, humanitarian expert, December 2020.

⁴⁴ The New Humanitarian, “Syria Cash Aid Freeze, Somali Biometrics, and Poverty Porn: The Cheat Sheet,” April 26, 2019.

⁴⁵ Interview, humanitarian expert, November 2020.

⁴⁶ See, for example, Norwegian Refugee Council, “Toolkit for Principled Humanitarian Action: Managing Counterterrorism Risks,” May 2020.

⁴⁷ See, for example, Joel Charny, “Counter-Terrorism and Humanitarian Action: The Perils of Zero Tolerance,” War on the Rocks, March 20, 2019, accessed June 22, 2025, https://tinyurl.com/perilsofzerotolerance.

⁴⁸ Charny, “Counter-Terrorism”; Norwegian Refugee Council, “Annual Report from the Board,” 2019.

⁴⁹ Micheletti, “Nous, humanitaires.”

⁵⁰ Katie King, Naz Modirzadeh, and Dustin Lewis, “Understanding Humanitarian Exemptions: UN Security Council Sanctions and Principled Humanitarian Action,” Harvard Law School Program on International Law and Armed Conflict, April 2016: 6; Mackintosh and Duplat; Jessica Burniske, Naz Modirzadeh, and Dustin Lewis, “Counter-Terrorism Laws and Regulations: What Aid Agencies Need to Know,” Humanitarian Practice Network, November 2014: 7.

⁵¹ Debarre, “Making Sanctions Smarter,” 14,16.

⁵² Debarre, “Making Sanctions Smarter,” Annex 2; Articles 6a(1) and 16a(1) of Official Journal of the European Union, “EU Council Regulation 36/2012,” January 18, 2012.

More recently, the UN adopted a permanent (it previously had to be regularly renewed) humanitarian exemption in its Somalia sanctions regime in 2020 (UNSC Resolution 2551) and introduced a humanitarian exemption to its Taliban-related sanctions in 2021 (UNSC Resolution 2615), and its Haiti Sanctions in October 2022 (UNSC Resolution 2653). There are also examples of humanitarian exemptions in counter-terrorism measures, for example in the 2017 EU Counterterrorism Directive, and more recently in counter-terrorism legislation in the Philippines, Chad, Ethiopia, and Switzerland.

⁵³ UNSC, “Adopting Resolution 2664 (2022), Security Council Approves Humanitarian Exemption to Asset Freeze Measures Imposed by United Nations Sanction Regimes,” S/RES/2664, December 9, 2022. For details on the negotiation, see Security Council Report, “Sanctions: Vote on Resolution Establishing a Standing Humanitarian Carve-out to UN Sanctions Regimes,” December 9, 2022.

⁵⁴ Office of Foreign Assets Control, “Addition of General Licenses to OFAC Sanctions Regulations for Certain Transactions of Nongovernmental Organizations and Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates for Medical Devices,” December 21, 2022; OFAC, “Addition of General Licenses for the Official Business of the United States Government and Certain International Organizations and Entities and Updates to the 50 Percent Rule Interpretive in OFAC Sanctions Regulations,” December 21, 2022.

⁵⁵ UK Parliament, “The Sanctions (Humanitarian Exception) (Amendment) Regulation 2023,” February 9, 2023, accessed November 26, 2024, www.legislation.gov.uk/uksi/2023/121/contents/made. It was accompanied by an explanatory memorandum. Note that as of writing, the UK has not introduced a horizontal exemption on the model of UNSC Resolution 2664 in its autonomous sanctions. It has, however, adopted humanitarian exemptions in some of its autonomous sanctions regimes, including in its counter-terrorism sanctions regime for humanitarian activities in relation to the conflict in Israel and the Occupied Palestinian Territory. See Office of Financial Sanctions Implementation (OFSI), General Licence: Israel, the Occupied Palestinian Territories, and Lebanon: Humanitarian Activity, INT/2023/3749168, November 14, 2023.

⁵⁶ “Article 1,” Official Journal of the European Union, “Council Decision (CFSP) 2022/627,” April 13, 2022; “Article 1, 1.2(a)” Official Journal of the European Union, “Council Decision (CFSP) 2022/628,” April 13, 2022.

⁵⁷ Official Journal of the European Union, “Council Decision (CFSP) 2023/338,” February 14, 2023; Official Journal of the European Union, “Council Decision (CFSP) 2023/726,” March 31, 2023. The EU also adopted a temporary humanitarian exemption to the financial restrictions of the EU Syria regime, which will run until February 2024. “Article 28(a)” of Official Journal of the European Union¸ “Council Decision (CFSP) 2023/408,” February 13, 2023; Official Journal of the European Union, “Council Decision (EU) 2023/1467,” July 14, 2023.

⁵⁸ European Council, Council Decision (CFSP) 2024/628 of 19 February 2024 Amending Common Position 2001/931/CFSP on the Application of Specific Measures to Combat Terrorism, February 20, 2024. Note that this humanitarian carve-out is time-limited to twelve months.

⁵⁹ See, ICRC, “UN Security Council’s adoption of a resolution protecting humanitarian activities,” Press Release, December 9, 2022; Norwegian Refugee Council, “New UN Security Council Humanitarian Exemption to Sanctions Will Help Save Lives,” Press Release, December 9, 2022.

⁶⁰ UNSC, “Letter dated 12 October 2020 from the Chair of the Security Council Committee pursuant to resolution 751 (1992) concerning Somalia addressed to the President of the Security Council,” S/2020/1004, October 15, 2020: 15; Moret, “Effectiveness”; Alice Debarre, “Safeguarding Humanitarian Action from the Unintended Effects of Sanctions: Resolution 2664 and the 1267 ISIL/al-Qaida Regime,” IPI, November 2024.

⁶¹ See, for example, the experience in Afghanistan where challenges persisted despite the presence of significant safeguards. See, “S/2023/370,” UNSC, June 1, 2023: 12; Erica Moret, “Barriers to Afghanistan’s Critical Private Sector Recovery,” Norwegian Refugee Council, March 2023; OHCHR, “Afghanistan: UN Experts Call on US Government to Unblock Foreign Assets of Central Bank to Ease Humanitarian Impact,” Press Release, April 25, 2022; Debarre, “Safeguarding Humanitarian Action: Resolution 2664 and the 1267 ISIL/al-Qaida Regime.”

⁶² See, for example, Caroline Crystal, “Landmark UN Humanitarian Sanctions Exemption is a Massive Win but Needs More Support,” Carnegie Endowment for International Peace, March 20, 2023; Emanuela Chiara-Gillard, “Humanitarian Exceptions: A Turning Point in UN Sanctions, Expert Comment,” Chatham House, December 20, 2022.

⁶³ UNSC Resolution 2664 (2022) directs the Council’s Committees on sanctions to issue Implementation Assistance Notices, “Article 6” of UNSC, “Adopting Resolution 2664 (2022), Security Council Approves Humanitarian Exemption to Asset Freeze Measures Imposed by United Nations Sanction Regimes,” S/RES/2664, December 9, 2022. The Harvard Law School Program on International Law and Armed Conflict has also published a detailed and comprehensive interpretive note of UNSC Resolution 2664. Radhika Kapoor, Dustin A. Lewirs, Naz K. Modirzadeh, “An Interpretive Note for U.N. Member States on Security Council Resolution 2664 (2022),” Harvard Law School Program on International and Armed Conflict, March 2023.

⁶⁴ See, for example, UNSC, “Final Report of the Panel of Experts,” S/2023/171, March 7, 2023: Annex 90.

⁶⁵ See, for example, ICRC, “ICRC Position on Humanitarian Carveouts and Authorization Systems Submission to the Standing Committee on Justice and Human Rights,” April 2023.

⁶⁶ Interview, humanitarian expert, November 2020; UNSC, “Final Report of the Panel of Experts submitted pursuant to resolution 2672,” Annex 90.

⁶⁷ Debarre, “Safeguarding Humanitarian Action: Resolution 2664 and the 1267 ISIL/al-Qaida Regime.”

⁶⁸ Note that in 2020, the UN’s Counter-Terrorism Directorate (CTED) started an initiative on the interrelationships between counter-terrorism and IHL. Under this initiative, CTED has solicited the UN Office for the Coordination of Humanitarian Affairs to work on a report on States’ practices in this area (including as relates to the implementation of sanctions) and consequences of this practice on humanitarian action. This will be the first official report on the issue drafted by a non-humanitarian UN entity and transmitted to a UNSC body. However, it is still up to the humanitarian sector to coordinate and provide the substance for the report.

⁶⁹ See, for example, “Detrimental Impacts,”; Mackintosh and Duplat; Burniske and Modirzadeh, “Pilot Empirical Survey”; Norwegian Refugee Council, “Principles under Pressure”; Gordon and Taraboulsi-McCarthy; Debarre, “Making Sanctions Smarter”; and McCarthy, “Survey Report.”

⁷⁰ Debarre, “Making Sanctions Smarter,” 7.

⁷¹ See, for example, Council of the EU, “Communication from the Commission to the European Parliament and the Council on the EU’s humanitarian action: new challenges, same principles, Council Conclusions 8966/21,” May 20, 2021: para 14.

⁷² See, for example, Micheletti “Nous, humanitaires.”

⁷³ Note, for example, that UNSC Resolution 2664 (2022) requests that humanitarian actors “use reasonable efforts to minimize the accrual of any benefits prohibited by sanctions to designated individuals or entities, including by strengthening risk management and due diligence strategies and processes.”

⁷⁴ Debarre, “Making Sanctions Smarter,” 30–32.

⁷⁵ Abby Stoddard, Monica Czwarno, and Lindsay Hamsik, “NGOs & Risk: Managing Uncertainty in Local–International Partnerships,” USAID, InterAction, and Humanitarian Outcomes, March 7, 2019, 25.

⁷⁶ The FATF is the body in charge of developing recommendations that serve as internationally endorsed global standards against money laundering and terrorist financing. FATF, “International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation: The FATF Recommendations,” 2012. The FATF also issued a statement supportive of nonprofit organizations when the Covid-19 pandemic started, FATF, “Statement by the FATF President: COVID-19 and Measures to Combat Illicit Financing,” April 1, 2020.

⁷⁷ FATF, “Protecting Non-profits from Abuse from Terrorist Financing through the Risk-Based Implementation of Revised FATF Recommendation 8,” November 16, 2023; U.S. Department of the Treasury, “De-risking Strategy,” April 2023; U.S. Department of the Treasury, “National Terrorist Financing Risk Assessment,” February 2024; UK HM Treasury and Home Office, “National Risk Assessment of Money Laundering and Terrorist Financing,” December 2020; European Commission, “Report on the Assessment of the Risk of Money Laundering and Terrorist Financing Affecting the Internal Market and Relating to Cross-border Activities,” October 27, 2022; UNSC, “Report of the Secretary-General, Implementation of Security Council Resolution 2664 (2022),” UN Doc. S/2023/658, September 8, 2023, 7–8.

⁷⁸ Debarre, “Making Sanctions Smarter,” 7, 32–33.

⁷⁹ See U.S. Agency for International Development, “Part I(4)” of “Certifications, Assurances, Representations, and Other Statements of the Recipient: A Mandatory Reference for ADS Chapter 303,” July 26, 2022.

⁸⁰ Some humanitarian organizations have partnerships with Directorates General beyond the Directorate General for European Civil Protection and Humanitarian Aid Operations, which include a problematic clause. See, for example, European Commission Directorate-General for International Partnerships, “Contract Procedures for European Union External Action – A Practical Guide,” December 2021; Emanuela-Chiara Gillard, Sangeeta Goswami, and Fulco van Deventer, “Screening of Final Beneficiaries – A Red Line in Humanitarian Operations: An Emerging Concern in Development Work,” International Review of the Red Cross 103 (916–917) (2021): 517–537.

⁸¹ For example, see, UNSC, “Resolution 1781 (2006),” S/RES/1718, October 14, 2006; UNSC Committee, “Implementation Assistance Notice No. 7: Guidelines for Obtaining Exemptions to Deliver Humanitarian Assistance to the Democratic People’s Republic of Korea,” June 2, 2023; UK Treasury OFSI, “Frequently Asked Questions: Factsheet for Charities and Other Non-governmental Organizations (NGOs)”; OFAC, “Supplemental Guidance for the Provision of Humanitarian Assistance, Supplementing the 2014 Guidance Related to the Provision of Humanitarian Assistance by Not-for-Profit Non-governmental Organizations,” February 23, 2023; and the UN Sanctions App was updated between 2021 and 2023 to include humanitarian issues.

⁸² See, for example, OFAC, “Factsheet: Provision of Humanitarian Assistance and Trade to Combat COVID-19,” April 2020; European Commission, “Commission Guidance Note on the Provision of Humanitarian Aid to Fight the COVID-19 Pandemic in Certain Environments Subject to EU Restrictive Measures,” November 16, 2020; European Commission, “Questions and Answers on the Provision of Humanitarian Aid to Fight the COVID-19 Pandemic in Syria,” 2023.

⁸³ UNSC, “Security Council Committee Established Pursuant to Resolution 1718 (2006), Implementation Assistance Notice No. 7: Guidelines for Obtaining Carve-Outs to Deliver Humanitarian Assistance to the Democratic People’s Republic of Korea,” June 2, 2023; UNSC, “Security Council Committee Established Pursuant to Resolution 1970 (2011) Concerning Libya, Implementation Assistance Notice #7: Guidance to Member States on the Application of the Humanitarian Carve-Out Established by Resolution 2664 (2022) to the Asset Freeze Established under Resolution 1970 (2011),” December 4, 2023; UNSC, “Security Council Committee Established Pursuant to Resolution 2713 (2023) Concerning Al-Shabaab, Implementation Assistance Notice #4: Guidance to Member States on the Application of the Humanitarian Carve-Out Established by Resolution 2664 (2022) to the Asset Freeze Established under Resolution 1844 (2008),” February 6, 2024; UNSC, “Security Council Committee Established Pursuant to Resolution 1533 (2004) Concerning the Democratic Republic of Congo, Implementation Assistance Notice #1: Guidance to Member States on the Application of the Humanitarian Carve-Out Established by Resolution 2664 (2022) to the Asset Freeze Established under Resolution 1596 (2005),” February 29, 2024; UNSC, “Security Council Committee Established Pursuant to Resolution 2127 (2013) Concerning the Central African Republic, Implementation Assistance Notice #2: Guidance to Member States on the Application of the Humanitarian Carve-Out Established by Resolution 2664 (2022) to the Asset Freeze Established under Resolution 2127 (2013),” March 14, 2024; UNSC, “Security Council Committee Established Pursuant to Resolution 1591 (2005) Concerning South Sudan, Implementation Assistance Notice #1: Guidance to Member States on the Application of the Humanitarian Carve-Out Established by Resolution 2664 (2022) to the Asset Freeze Established under Resolution 2206 (2015),” March 1, 2024. IANs have not been developed for the ISIL/al-Qaida, Iraq, Sudan, 1636 (2005 Beirut bombing), Taliban, Guinea-Bissau, Yemen, and Haiti sanctions regimes.

⁸⁴ For the US guidance, see OFAC, “Supplemental Guidance for the Provision of Humanitarian Assistance,” February 23, 2023. For the EU guidance, see European Commission, “Frequently Asked Questions: Humanitarian Carve-Out in the EU Syria Sanctions Regime Following the February 2023 Earthquakes in Turkiye and Syria,” 2023.

⁸⁵ Debarre, “Making Sanctions Smarter,” 27, 29; Debarre, “Safeguarding Humanitarian Action: Resolution 2664 and the 1267 ISIL/al-Qaida Regime.”

⁸⁶ Debarre, “Making Sanctions Smarter,” 21–23. See also Lia van Broekhoven and Sangeeta Goswami, “Can Stakeholder Dialogues Help Solve Financial Access Restrictions Faced by Non-profit Organizations That Stem from Countering Terrorism Financing Standards and International Sanctions?” International Review of the Red Cross 103 (916–917) (2021): 733–736; Sue E. Eckert and Jacob Kurtzer, Mitigating Financial Access Challenges – Proposals from the CSIS Multi-stakeholder Working Group on Financial Access, Report, Center for Strategic & International Studies, October 2022, 21–23, www.csis.org/analysis/mitigating-financial-access-challenges.

⁸⁷ World Bank, “Stakeholder Dialogue on De-risking: What Will It Take to Safeguard Financial Inclusion?” May 31–June 1, 2016.

⁸⁸ Geneva Graduate Institute, “Compliance Dialogue on Syria-Related Humanitarian Payments,” January 2019. The dialogue culminated with the publication of a guide. See, Walker, “Risk Management.”

⁸⁹ Erica Moret, “The Developing Role of National Tri-sector Groups in Addressing Financial Derisking,” Norwegian Refugee Council, January 2024.

⁹⁰ Van Broekhoven and Goswami, “Can Stakeholder Dialogues Help,” 745–746.

⁹¹ Debarre, “Making Sanctions Smarter,” 7.

⁹² Debarre, “Safeguarding Humanitarian Action from the Unintended Effects of Sanctions: Resolution 2664 and the 1267 ISIL/al-Qaida Regime.”

⁹³ Pax for Peace, “Controversial Arms Trade and Investments of Dutch Banks,” June 6, 2019; NATO Parliamentary Assembly, “Assembly, Development and Security Challenges in the Sahel Region,” April 10, 2020: 5; L’indépendant, “Les terroristes se dotent de nouveaux équipements militaires: Des dispositifs de surveillance (appartenant aux militaires français) retrouvés dans la région de Kidal,” August 31, 2020; ISS Africa, “Where Do Sahel Terrorists Get Their Heavy Weapons?” February 12, 2020.

⁹⁴ ICRC, “Arms Availability and the Situation of Civilians in Armed Conflict,” ICRC Publication Ref. 0734, 1999.

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