WASHINGTON — Governments and relief agencies are calling for a tighter, clearer approach to sanctions that blocks wars and corruption without freezing civilians out of food, medicine and money. The blueprint: define what success looks like, enforce restrictions that can be enforced and write humanitarian carve-outs so banks and suppliers can keep delivering basics, Dec. 27, 2025.
Sanctions have become a default response to aggression, coups and terrorism financing. But officials, banks and aid groups say the tool can backfire when rules are vague, enforcement is uneven and “de-risking” leads companies to pull back even from legal humanitarian work.
Sanctions need clear goals and measurable off-ramps
When penalties are piled on without a realistic end state, they can harden targets, frustrate allies and dilute credibility. A 2021 U.S. Treasury sanctions review urged policymakers to link sanctions to a clear objective within a broader strategy and to design measures that are “easily understood, enforceable, and, where possible, reversible.”
A practical test for any new package is whether officials can answer three questions up front:
What behavior must change, and by whom?
What would partial success look like in 90 days and one year?
What concrete steps would trigger easing or lifting the sanctions?
Sanctions enforcement: make evasion harder than compliance
Enforcement is where ambitious policy often breaks down. Evasion networks exploit lightly regulated intermediaries, weak corporate transparency and fragmented cross-border investigations. Treasury’s review also flagged new challenges from faster payment systems, digital assets and cybercriminals.
A tougher enforcement posture does not have to mean broader sanctions. It can mean:
targeting the brokers, shippers and financial gatekeepers that help sanctioned actors move money and goods;
coordinating designations, evidence standards and penalties with close partners to reduce “safe havens”; and
publishing clearer, faster compliance guidance so legitimate trade is not punished by uncertainty.
Humane sanctions carve-outs that work in practice
Humanitarian safeguards have moved from ad hoc exceptions to a more formal architecture. The U.N. Security Council adopted Resolution 2664 in December 2022, creating a standing humanitarian exemption from certain U.N. asset freezes for transactions needed to deliver humanitarian assistance and support basic human needs. The council later extended the exemption for the ISIL (Daesh) and al-Qaida regime in December 2024.
In the United States, Treasury’s sanctions programs increasingly rely on general licenses and guidance meant to keep lawful aid moving. OFAC’s 2023 supplemental guidance for humanitarian assistance, which built on its 2014 NGO guidance, is intended to reduce uncertainty for nonprofit groups and their private-sector partners.
Still, the humanitarian problem is often less about what is legal than what is bankable. A 2019 International Peace Institute report described “de-risking” as banks cutting off or restricting services in sanctioned contexts, delaying programs and pushing aid groups toward cash-based workarounds.
Europe has been moving in the same direction. An ICRC analysis of the EU’s 2023 shift described wider standing humanitarian exemptions, while warning that exemptions will not curb overcompliance without consistent interpretation and outreach.
The approach is also being tested in live crises. Reuters reported that the United States issued a six-month general license for certain transactions with Syria’s governing institutions after the collapse of Bashar al-Assad’s rule, and quoted then-Deputy Treasury Secretary Wally Adeyemo saying, “During this period of transition, Treasury will continue to support humanitarian assistance and responsible governance in Syria.”
A workable blueprint would not make sanctions painless or universally effective. But it would make them easier to explain, harder to dodge and less likely to punish civilians for decisions they did not make.
