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Licence to aid: the legal and compliance challenges of UNSCR 2664 for UK-connected financial institutions
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This article explores the legal and compliance challenges surrounding United Nations Security Council Resolution 2664 (2022). This resolution introduces a standing humanitarian exemption to asset freeze measures across all United Nations sanctions regimes marking a significant evolution in international sanctions law. This exemption is intended to safeguard the delivery of humanitarian assistance in sanctioned jurisdictions. This article argues that while United Nations Security Council Resolution 2664 (2022) is a positive development in facilitating humanitarian activities within sanctioned jurisdictions, its effectiveness is limited by its exclusion from the UK’s autonomous sanctions regime. In practice, this means that UK-connected financial institutions are unable to operationalise the humanitarian exemption to facilitate humanitarian activities undertaken by humanitarian actors.
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