Helfen statt Blockieren
DEENES
Menu

Knowledge, Topic sheet

Humanitarian aid and aid organisations

· Helfen statt Blockieren editorial team

For aid organisations the legal situation has improved markedly since 2022. Today the biggest obstacle is often not the ban but the route of the money: banks that refuse permitted payments anyway.

What is blocked

  • Afghanistan: Before the UN humanitarian exemption of December 2021, banks feared breaching domestic law or US sanctions by moving humanitarian funds1.

What is expressly allowed

  • UN: Resolution 2664 of 9 December 2022 makes clear that funds and services for humanitarian aid and basic human needs are not covered by UN asset freezes. 14 states voted in favour, India abstained2.
  • UN: With Resolution 2761 of 6 December 2024 the exemption also applies indefinitely in the ISIL and Al-Qaida regime34.
  • EU: With Regulation 2023/331 of 14 February 2023 the EU took this exemption into its regimes that implement UN lists5.
  • EU: On 19 February 2024 the Council also introduced a humanitarian exception in the EU counter-terrorism framework, initially for twelve months6.
  • US: On 20 December 2022 the Treasury issued general licenses in programmes that had no humanitarian exception, among others for agricultural commodities, medicine and medical devices7.
  • EU: On 30 June 2022 the Commission published a horizontal guidance note on humanitarian aid under EU sanctions8.

What still does not arrive

  • Afghanistan: Even after the December 2021 exemption few banks accepted transfers. A representative of InterAction said they just did not want to get involved1.
  • Cuba: After Hurricane Melissa, Cuba reportedly received 20 to 25 times less funding than Jamaica, according to information given to Douhan9.

Documented examples

  • SyriaAfter the earthquakes of 6 February 2023 the US issued General License 23 for 180 days on 9 February 202310; on 16 May 2023 the EU published questions and answers on its exemption11.
  • USIn 2017 two thirds of surveyed US aid organisations had problems with banks12.
  • WorldwideOn the first anniversary the Norwegian Refugee Council wrote that Resolution 2664 had allowed it to support people more efficiently, effectively and safely13.

Counterpoints: why states impose sanctions

  • India abstained on Resolution 2664 in 2022, concerned that terrorist groups could misuse the exemption2.
  • UN: The exemption does not lift the lists. Sanctions on ISIL and Al-Qaida remain; Resolution 2761 only makes the humanitarian exemption within them permanent4.

Figures marked “according to information given to” are not the cited body’s own measurements but information presented to it.

This page is information, not legal advice. It reports what authorities, courts, governments and organisations decide and say; the views of the side imposing measures and of the side affected stand side by side. “Helfen statt Blockieren” is non-partisan. Please report errors to info@aciel-martinez-poll.com.

Sources

  1. Devex (David Ainsworth), “Sanctions and banks make it a struggle to get money into Afghanistan”, 17 Jan 2022. https://www.devex.com/news/sanctions-and-banks-make-it-a-struggle-to-get-money-into-afghanistan-102448
  2. UN Security Council, press release SC/15134 (9214. meeting), Report on the adoption of Resolution 2664 (2022), 9 Dec 2022. https://press.un.org/en/node/311942
  3. UN Security Council, press release SC/15924 (9802. meeting), Report on the adoption of Resolution 2761 (2024), 6 Dec 2024. https://press.un.org/en/2024/sc15924.doc.htm
  4. IPI Global Observatory, “An Indefinite Humanitarian Carve-out for the ISIL/al-Qaida UN Sanctions Regime: What it Means and What Comes Next”, December 2024. https://theglobalobservatory.org/2024/12/resolution2761-indefinite-humanitarian-carveout-un-sanctions-regime/
  5. Council of the EU, Regulation (EU) 2023/331 of 14.2.2023 amending certain regulations concerning restrictive measures in order to insert provisions on a humanitarian exemption, OJ L 47 of 15.2.2023, S. 1, 14 Feb 2023. https://eur-lex.europa.eu/eli/reg/2023/331/oj
  6. Council of the EU, press release, as reproduced by ieu-monitoring, “Humanitarian action: EU introduces further exception to sanctions”, 19 Feb 2024. https://ieu-monitoring.com/editorial/humanitarian-action-eu-introduces-further-exception-to-sanctions/428749/
  7. US Treasury, press release JY1175, “Treasury Implements Historic Humanitarian Sanctions Exceptions”, 20 Dec 2022. https://home.treasury.gov/news/press-releases/jy1175
  8. European Commission, “Commission Guidance Note on the provision of humanitarian aid in compliance with EU restrictive measures (sanctions)”, 30 Jun 2022. https://commission.europa.eu/system/files/2022-06/220630-humanitarian-aid-guidance-note_en.pdf
  9. OHCHR, Special Rapporteur Alena Douhan, Preliminary findings of the visit to Cuba, end of mission statement, 11 to 21 November 2025, 21 Nov 2025. Many figures there are marked “reportedly”, i.e. based on information presented to her. https://www.ecoi.net/en/file/local/2133521/20251121-eom-stm-cuba-sr-negative-impact-unilateral-en.pdf
  10. US Treasury, press release JY1261, “Treasury Issues Syria General License 23 To Aid In Earthquake Disaster Relief Efforts”, 9 Feb 2023. https://home.treasury.gov/news/press-releases/jy1261
  11. European Commission (financial services), “Humanitarian assistance in environments subject to EU sanctions”, 3 Nov 2026. Overview of guidance, incl. FAQs on Russia (7 Feb 2023) and on the Syria earthquake (16 May 2023). https://finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures/humanitarian-assistance-environments-subject-eu-sanctions_en
  12. Devex (Sophie Edwards), on the survey by Charity & Security Network, “De-risking is causing significant banking problems for two-thirds of US nonprofits”, 14 Feb 2017. https://www.devex.com/news/derisking-is-causing-significant-banking-problems-for-two-thirds-of-us-nonprofits-89631
  13. Norwegian Refugee Council, Statement on the first anniversary of Resolution 2664, 15 Dec 2023. https://www.nrc.no/news/2024/december/un-security-council-humanitarian-exemption-to-sanctions

All online sources accessed on 3 November 2026.

All topics