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
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
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
- 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
- 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
- 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
- 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/
- 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
- 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/
- US Treasury, press release JY1175, “Treasury Implements Historic Humanitarian Sanctions Exceptions”, 20 Dec 2022. https://home.treasury.gov/news/press-releases/jy1175
- 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
- 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
- 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
- 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
- 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
- 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.
