Articles by author
Licence to aid: the legal and compliance challenges of UNSCR 2664 for UK-connected financial institutions
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.
22 MAY 2026Governing law, ungovernable questions: the challenge of public international law in the World Bank’s development policy financing agreements
This article explores the challenges surrounding governing law in the World Bank’s development policy financing agreements (ie loan, credit, guarantee and the International Development Association’s grant and financing agreements). Multilateral development banks, such as the World Bank, play a critical role in addressing global development challenges in low- and middle-income countries. The World Bank (and indeed certain other multilateral development banks owing to their nature as supranational entities) adopts public international law as the governing law for its development policy financing agreements. English law or New York law are usually used in standard loan agreements due to their predictability, clarity and well-established precedents. The World Bank’s use of public international law – while aligned with its supranational status – raises questions around enforceability, jurisdiction and dispute resolution. The article describes the role of public international law in governing the World Bank’s development policy financing agreements and its practical application.
29 SEP 2025
