Sanctions as Barriers to the Work of Humanitarian Organizations

Abstract

Throughout thirteen years of conflict, Syria was experiencing one of the world’s major humanitarian crises, necessitating a vast humanitarian response involving various UN agencies and (inter)national and local nongovernmental organizations (INGOs, NGOs). Humanitarian operations in Syria faced numerous challenges, with sanctions and unilateral measures being prime examples. Despite the theoretical availability of humanitarian exemptions, the semi- comprehensive sanctions and donor conditionality directly and indirectly hindered humanitarian efforts. Drawing on various data, the chapter illustrates how sanctions created obstacles for humanitarian work falling into three categories: financial challenges related to money transfer due to overcompliance and de-risking; legal challenges linked to due diligence, compliance requirements, and interpretation of sanctions; and operational challenges related to “dual-use” regulations, “State Sponsor of Terrorism” designation, as well as direct sectoral sanctions. The chapter further highlights the limitations of humanitarian exemptions, arguing that they fail to effectively mitigate the negative impact of sanctions. Additionally, the chapter elaborates on the indirect impact of sanctions with regard to oil supplies and currency depreciation and fluctuations. It emphasizes the urgent need for sanctioning states to actively engage in protecting and insulating the work of humanitarian organizations, and raises the question of accountability for the impact of sanctions on aid beneficiaries.