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Author Dr Mark Daniel Jaeger
Some humanitarian transfers to regions impacted by sanctions and counterterrorism (CT) measures encounter significant risks related to sanctioned parties, the activities of designated terrorist groups and other financial crime. Managing these risks is a complex challenge. Transfers continue to face frequent delays, often of several months, or they may fail entirely.ii This jeopardises effective responses to humanitarian emergencies. There has been substantial progress in recent years in the establishment of broad humanitarian exemptions, most importantly UN Security Council resolutions 2664 and 2761, and the issuing of more guidance from regulators, including the European Union (EU), the United Kingdom (UK) and the United States (US). Transfers, however, still face difficulties, whether they are to field offices or suppliers or for staff salaries. Thirty-two per cent of payments to Syria in 2023, for example, were delayed for between three and ten months.iii