The state of targeted financial sanctions on humanitarian action

In 2024 the Human Security Collective conducted a mapping exercise commissioned by the Dutch Ministry of Foreign Affairs to assess the impact of UNSC Resolution 2664 and European targeted sanctions regimes on the humanitarian work of DRA members and beyond. In collaboration with KUNO, HSC circulated a questionnaire and conducted interviews with humanitarian organizations, EU and UN policymakers, and banks which resulted in a report that was presented to the EU Relex sanctions working group in 2024 at the intermediate stage under the Belgian presidency and final stage, together with the Norwegian Refugee Council,  under the Hungarian presidency. The findings were also briefly shared at the Sanctions Knowledge Network event organized by Clingendael on January 17th.  

In December 2024 the UNSC adopted resolution 2761, extending the application of the carve-out to the 1267 ISIL/al-Qaida counterterrorism regime indefinitely. Resolution 2664 was a milestone decision that represented a fundamental policy shift within the council aimed at safeguarding humanitarian action from the unintended effects of sanctions. Resolution 2761 is just as significant. 

The sanctions regimes on Syria have proven to be among the most complicated and have significantly hindered humanitarian action. With the ending of the Assad regime and the takeover by HTS, important sanctions imposed by the EU against Syrian banks, energy and transport companies are being lifted. The US and UK sanctions are still largely intact.  However, the situation on the ground remains complex, and the risk appetite of the financial institutions like banks and money transfer businesses,  and others in the private sector to facilitate money transfers to and invest in the country continues to be low.  The developments in Afghanistan in relation to transferring money after the takeover by the Taliban may be insightful for the current situation in Syria. 

• To share the results of the Human Security Collective report with DRA members, other NPOs, e.g. NRC, Caritas Europe, Voice, and other stakeholders, e.g. policy makers, bankers that took part in the survey or were interviewed. 

• To discuss current developments regarding the harmonization of UNSC Resolution 2664 in European sanctions regimes in policy and practice with DRA members, other NPOs, policymakers, and banks. The recent lifting of specific sanctions in Syria can serve as a timely and pertinent case study for the discussion, with reflections from experiences on Afghanistan to inform the conversation. 

• To provide practical recommendations for the participants, that could help them to navigate sanction regimes for humanitarian activities.

• Lia van Broekhoven, Executive Director, Human Security Collective 

• Fulco van Deventer, Vice Director, Human Security Collective 

The session will be moderated by Mohammad Kanfash, PhD-candidate at the Center for Conflict Studies and lecturer on the Politics of Reconstruction at Utrecht University. 

Please register via kuno@kuno-platform.nl.