This paper argues that the current framework permitting humanitarian transactions into sanctioned and conflict environments needs re-thinking and updating.
This paper is based on in-depth interviews conducted with banks, humanitarian actors, regulators and government officials. It incorporates a review of relevant literature and has involved extensive field-based observations including with jurisdictions experiencing conflict or subject to sanctions.
This paper finds that a recalibration of the sanctions architecture is required and that a new equilibrium needs to be created to ensure the ability of international banks to support permissible humanitarian and development payments. It further sets out that the foreign policy intention of economic sanctions, when combined with licensing complexity and other risk factors, such as terrorist financing, are not achieving their intended goals.
Assessment on the strategic importance of ensuring access to financial services for jurisdictions subject to sanctions and in conflict.
