Author Dr. Erica Moret, Senior Researcher, Sanctions and Sustainable Peace Hub, Geneva Graduate Institute & Policy Director, Polisync – Swiss Centre for International Policy Engagement Acknowledgement
The author thanks all those who generously gave their time to help inform this study, including through interviews and various rounds of feedback on earlier drafts. A special thanks to Ivonne Duarte Peña, Political Affairs Officer at the UN Office of the Special Envoy for Syria, Julien Piacibello, Humanitarian Affairs Officer at UN-OCHA and the Syria Resource Group (SRG) supported by the Institute for Integrated Transitions (IFIT), for Integrated Transitions (IFIT), for their particularly detailed and expert inputs offered in a personal capacity. All efforts were made to triangulate findings, but the author accepts responsibility for any errors that may remain.
Executive Summary
The adoption of several humanitarian carveouts under several Syria-related autonomous sanctions regimes – in response to February 2023’s devastating earthquake – has been strongly welcomed by the humanitarian community. The exceptions adopted by the United States (US),
European Union (EU), United Kingdom (UK), and Switzerland are designed to facilitate transactions in relation to relief efforts and the purchase of oil and petroleum-related products in Syria, particularly by humanitarian actors. They differ in terms of scope of activities authorized, breadth of actors covered, and their duration. This article seeks to map the main characteristics of each exception and assesses them in terms of benefits, ongoing challenges, and areas for potential improvement to inform future sanctions policies. It is based on 12 anonymized consultations and a series of additional consultations of over 20 non-governmental organizations (NGOs) via focal points of umbrella NGO organizations and other public bodies conducted between March-May 2023 with humanitarian and development actors, i banks and other financial institutions, and government representatives, operating in or on affected areas in Syria.