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After outlining some of the key humanitarian concerns stemming from the contemporary sanctions and wider regulatory landscape, this paper highlights recommendations for future action. These recommendations range from more strategic policy and regulatory changes that could be made at the source of the problem, namely the largely unaddressed interface challenge between government and the financial sector through improved guidance and training, to the more tactical “sticking plaster” end of the scale, including in relation to humanitarian banking channels, special purpose vehicles (SPVs), stand-alone humanitarian banks, and the role for new technologies and other innovations in allowing funds to reach high risk jurisdictions. It does so through a review of over 40 multi-stakeholder initiatives and research projects that have been underway over the past decade in seeking to address problems associated with de-risking, as well as through anonymized semi-structured interviews with over 30 sanctions, humanitarian, regulatory and banking specialists and practitioners conducted between early 2018 and early 2021.

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