This paper describes the challenges faced by the humanitarian community and proposes recommendations for a new framework. The paper is based on literature and policy reviews on the topic and is informed by interviews with small, medium, and large INGOs almost exclusively operating in Syria’s government-controlled areas (with few of them having cross-line operations). The first section of the paper lays out the background and rationale. The second section examines the various challenges faced by humanitarian actors in navigating sanctions exceptions. The third section focuses on additional factors affecting the humanitarian response, including the impact of COVID-19 and the newly enforced Caesar Act. A final section of the paper provides a range of recommendations for an improved, streamlined and expedited humanitarian response.