Mitigating the Adverse Impact of U.S. and United Nations Sanctions on the Delivery of Humanitarian Assistance

For over two decades, humanitarian organizations have raised alarm over the financial sector closing their accounts or blocking funds transfers to countries where individuals and groups subject to sanctions reside. This “de-risking” affects two-thirds of NGOs. Recently, the United States spearheaded humanitarian carveouts in UN sanctions regimes under Security Council resolution 2664 (2022) and across U.S sanctions via U.S. general licenses. Based on 50 interviews with government officials, financial institutions, NGOs, the UN, and experts, the Capstone team found that banks remain reluctant to process humanitarian payments. The team developed seven recommendations to resolve this challenge: 1. Communicate the prioritization of humanitarian transactions; 2. Advance the U.S. Multi-Stakeholder Working Group on Financial Access; 3. Mitigate humanitarian transactions’ legal risks; 4. Encourage implementation of resolution 2664 & amend UN counterterrorism frameworks; 5. Promote proactive response of enforcement actors; 6. Include humanitarian variables in the National Risk Assessments; 7. Streamline interagency sanctions coordination.