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European Commission




QUOTE OF COMMISSIONER: “Sanctions should not impede the delivery of humanitarian assistance, including medical assistance, in line with International Humanitarian Law. Providing clarity is a step forward to addressing the many challenges humanitarian actors face to deliver assistance on the ground, in contexts like Syria.” (Janez Lenarčič, Commissioner for Crisis Management, May 2020) 


The Commission has a specific mandate according to the Treaties to comply with humanitarian principles stemming from international law in its humanitarian operations.

Article 214(2) of the TFEU states that: “humanitarian aid operations must be conducted in compliance with the principles of international law and with the principles of impartiality, neutrality and non-discrimination”

When humanitarian operators subject to EU law implement actions in environments in which sanctions apply, they have to comply both with the obligations stemming from EU sanctions and with the humanitarian principles. EU sanctions should not stand in the way nor impede the delivery of humanitarian assistance. 

However, reconciling in practice the respect of IHL and humanitarian principles with compliance with obligations stemming from EU sanctions and counter terrorism measures can be complex. 

Sanctions explicitly seek to prevent persons subject to them from accessing, directly or indirectly, any sort of funds or economic resources, to avoid that those resources are used for forbidden purposes.  EU sanctions regulations provide certain safeguards aimed at ensuring that every sanctioned person can nevertheless access the resources needed to cover their basic needs. Moreover, respect of humanitarian principles, in particular the obligation to help those in need irrespective of who they are, means that sanctioned persons which qualify as “persons in need” can receive humanitarian aid. Humanitarian operators must make the identification of individuals in need solely based on the humanitarian principles of humanity, impartiality, independence and neutrality. Once this identification has been made, no further vetting of final beneficiaries against EU sanctions is required. Vetting or screening means the same, i.e. checking whether the person is listed in sanctions regimes.

As reported by partners, sanctions may cause broader, unintended impact on the delivery of humanitarian assistance. This translates in daily operational difficulties as well as more indirect effects (i.e. over-compliance, de-risking) for them, which affect the delivery of humanitarian aid.  The issue of the impact of sanctions on the delivery of humanitarian assistance has received considerable attention from the international community.

The Commission is committed to fully support operators to abide by EU sanctions and to address these issues arising from the balancing exercise of provision of humanitarian aid while ensuring compliance with EU sanctions contexts.