Abstract

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, banks and other financial institutions, and government representatives, operating in or on affected areas in Syria.

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