The EU Council is to modify certain EU restrictive measures in keeping with UN Security Council resolution 2664 (2022) provisions for a humanitarian exemption to asset freeze measures in UN sanctions regimes. This will mean that specific categories of humanitarian actors, including UN programmes and non-governmental organisation participating in UN humanitarian response plans, can engage in transactions with listed individuals and entities without any need for prior authorisation, where the purpose is to deliver humanitarian assistance or to support other activities that support basic human needs.
The EU Council’s March 31 decision applies the exemption to 14 UN sanctions regimes transposed into EU law as well as to existing EU autonomous listings that complement the UN designations.
Operators will no longer have to distinguish between EU and UN listings. The exemption sends a strong signal that EU sanctions do not impede delivery of humanitarian assistance. It shows that the EU is resolutely committed to avoiding unintended negative consequences of sanctions on humanitarian activities.
