Scholars and humanitarians work together to mitigate the unintended impacts of UN sanctions

A collaboration project developed with GSPI’s support has driven considerable progress on facilitating the access to sanctions-related knowledge for humanitarian actors, thus empowering them to effectively pursue their work on the ground. Watch the video feature below.

‍The United Nations Security Council (UNSC) has significantly increased its application of sanctions as a tool for international conflict management since the 1990s. These measures have different goals and can take different forms, ranging from arms embargoes, restrictions on certain economic sectors and travel bans to asset freezes targeting individuals and groups involved in conflicts and violations of international law. As an example, multiple sanctions regimes have been imposed on entities in Libya due to the ongoing civil war and human rights abuses.

The “chilling effect” of UN and autonomous sanctions

However, these tools have been increasingly impacting humanitarian action in targeted countries. In particular, humanitarian actors have been facing financial and logistic hurdles to deliver aid to vulnerable populations. Because banking institutions tend to over-comply to avoid any risk, they can block financial transactions regardless of the existence of some humanitarian exemptions.

“Sanctions can block our efforts to transfer funds needed to sustain our activities into our areas of operations. In 2022, NRC experienced a 55% increase in the number of financial transfers being blocked by banks in the corresponding banking system from our Head Office to country offices, staff, and suppliers. It is now taking months to resolve delayed payments,” said Cherise Chadwick, policy advisor at the Norwegian Refugee Council.

Humanitarians themselves often struggle to understand the scope of permissible activities allowed under exemptions and derogations, leading to serious and long-term challenges for both aid workers and communities in need of assistance.To increase humanitarians’ capacities to navigate the sanctions environment, it is vital to ensure they can access tailored knowledge on the sanctions regimes. It is equally important to provide the diplomatic community and sanctions designers with accurate information on the impact that sanctions can have on humanitarian work to ensure better consideration of these consequences.

Getting scholars and humanitarians around the table

To address these challenges, the Global Governance Centre (GGC) at the Geneva Graduate Institute and the Norwegian Refugee Council (NRC) collaborated, between 2021 and 2023, on a project to empower humanitarian actors to effectively navigate the sanctions environment. The primary goal of the project was to foster interaction across the scholarly-humanitarian-policy divide to generate new, policy- and practice-relevant scientific data on the subject and ensure their effective dissemination, including through the UN Sanctions App.

The core collaboration enabled partners to leverage each other’s distinct experiences, networks and capacities. Humanitarian actors from the NRC benefitted from the research capacity and expertise of academic partners whilst allowing the latter to learn from humanitarian actors’ operational experience. Each partner was also able to mobilise key stakeholders: sanctions coordinators in the UNSC member states, policy practitioners, key humanitarian organisations and the extended community of scholars working on UN sanctions

A collaborative process

Swinging into action. The project started with an inception workshop for the cross-training of sanctions scholars and humanitarian practitioners. This meeting was key to generate trust and allow humanitarians to share qualitative and quantitative data about their operational experiences with academics. This in turn enabled academics to identify specific needs for practice-relevant information: guidelines, list and interpretation of exemptions, glossary of common terms, links to specialised legal advice, sources of information, etc.‍

Gathering resources. A mixed working group was created to oversee the knowledge production process. GGC scholars conducted research on all current UN sanctions regimes and available humanitarian exemptions, including individual Member States’ domestic implementation of UN sanctions. They also collected information and guidance from governments and regulatory bodies, to help humanitarian organisations understand the scope of sanctions as well as measures taken by States to help mitigate their unintended consequences.‍

Producing tailored knowledge products. The available guidance was assembled into a comprehensive list of relevant guidelines, reports and published studies which will be hosted online by NRC. The GGC updated the UN Sanctions App with relevant additions on humanitarian exemptions, turning the app into a practical tool for humanitarians. It also included relevant evidence on the potential impact of UN sanctions on the civilian population and humanitarian responses to support the work of diplomats within the UNSC.

Promoting long-term engagement. Partners convened a closing workshop attended by more than 80 participants including select representatives from the UNSC Member States to share the outcomes of the project, promote the use of the new material and identify areas for further research and collaboration. The event included a public panel with high-level representatives from UNOCHA, USAID, and the ICRC to encourage further dialogue between the diplomatic and humanitarian community on the future action. It discussed more specifically the UNSC Resolution 2664. Adopted in December 2022, this resolution establishes for the first time a “humanitarian carve-out” for asset freeze measures across all UN sanctions regimes. Monitoring its domestic application and measuring its effectiveness on the ground will require further collaboration between scholars, humanitarians and diplomats in future.

Towards sustained collaborative work

The project provided key stakeholders with evidence and targeted information to more effectively advocate and work on solutions to the unintended consequences of sanctions.

• UN Member States’ representatives and policy practitioners increased their awareness about the impacts of sanctions on humanitarian activities and received suggestions for potential improvements to the UN sanctions.
• Major humanitarian organisations improved their capacity to effectively navigate the increasingly complex regulatory environment linked to sanctions. Smaller NGOs who do not have the capacity to conduct research will also benefit from the project.
• Scholars working on UN Sanctions increased their understanding of the operational challenges that sanctions can have on principled humanitarian action.

Overall, this project generated cross-synergies between partners and their respective communities. Given their shared commitment to mitigate the negative consequences of sanctions on communities in need of humanitarian assistance and their wide network of influential stakeholders, the collaboration partners envision to contribute further to the improvement of sanctions design in the future.