Humanitarian Carveouts — Protecting Life Beyond Sanctions
“Even wars have limits. The protection of civilians is not a choice — it is a duty.” — United Nations Secretary-General António Guterres
Existing Situation
Economic sanctions are among the most frequently used tools of international diplomacy, intended to pressure governments and non-state actors toward lawful and peaceful behaviour. Yet when applied broadly or without humanitarian exceptions, sanctions can unintentionally restrict access to food, medicine, energy, and critical services for innocent civilians. Humanitarian organizations often face legal and financial barriers that delay or prevent lifesaving aid deliveries in sanctioned regions, even when the intent of the sanctions is purely political.
Diagnose Impact
The absence of clear humanitarian carveouts has turned sanctions into blunt instruments that sometimes deepen the very crises they aim to resolve. Millions endure shortages of essential goods, banking channels for aid collapse, and international NGOs withdraw for fear of legal repercussions. Such collateral harm erodes global confidence in collective action and weakens the moral legitimacy of sanctions regimes. When compassion becomes hostage to compliance, multilateralism loses both its heart and its credibility.
Roles of Each Nation
Every Member State has a role in reconciling enforcement with empathy. Sanction-imposing nations must incorporate automatic humanitarian exemptions into all new and existing regimes, covering food, medical supplies, water systems, education, and basic financial transfers for relief. Neutral and non-aligned states can act as conduits for vetted humanitarian trade, ensuring compliance without obstruction. The General Assembly should establish a transparent reporting mechanism — a global registry of humanitarian carveouts — where all states can document and monitor the implementation of these safeguards.
Prescribe the Change
We call for the formal adoption of Universal Humanitarian Carveouts in all UN-mandated and unilateral sanctions regimes. These carveouts should be standardized, automatically triggered, and shielded from political discretion. A standing technical panel — jointly convened by the UN Office for the Coordination of Humanitarian Affairs (OCHA) and the Peacebuilding Commission — should review compliance, identify blockages in aid delivery, and recommend adjustments in real time. Financial institutions participating in humanitarian transfers should be provided with legal guarantees against secondary penalties.
Show the Outcome
When humanitarian carveouts are universal, the world will no longer have to choose between justice and mercy. Sanctions will regain moral precision — targeting perpetrators without punishing the innocent. Aid agencies will operate with confidence and speed, lives will be saved, and public faith in international norms will be renewed. The UN’s credibility will grow stronger as it demonstrates that accountability and compassion are not competing values but complementary obligations.
5-Step Action Framework for Universal Humanitarian Carveouts
Step 1 — Establish the Core Task Force
Lead: UN OCHA + Peacebuilding Commission (PBC)
Supporting: Switzerland, Norway, Ireland, Singapore (neutral mediators), selected NGOs (ICRC, MSF, CARE, WFP Legal Units)
- Convene a Technical Drafting Group (TDG) to define standard carveout language for all sanctions frameworks.
- Draft model clauses and compliance templates usable by both UN and unilateral sanctioning bodies.
- Launch within 60 days, deliver first draft within 6 months.
Deliverable: “Model Universal Humanitarian Carveout Framework” document, ready for endorsement.
Step 2 — Secure Political Endorsement and Sponsorship
Lead: UN Permanent Missions of Switzerland and Costa Rica (champions of humanitarian law)
Supporting: OCHA Policy Unit, EU External Action Service, African Union Peace and Security Council
- Table a UN General Assembly Resolution calling for voluntary adoption pending Security Council review.
- Coordinate diplomatic briefings with sanction-imposing blocs (EU, US, UK, Canada) and non-aligned group.
- Integrate language into the upcoming GA Humanitarian Matters session.
Deliverable: GA Resolution recognizing the Universal Humanitarian Carveout principle.
Step 3 — Build the Global Registry of Carveouts
Lead: UN DESA + OCHA Financial Tracking Service (FTS)
Supporting: World Bank Sanctions Secretariat, OECD DAC, civil-society monitors
- Create an online public registry listing all sanctions regimes and their explicit humanitarian exemptions.
- Add status indicators: Implemented / Pending / Missing / Under Review.
- Require annual updates by Member States and regional organizations.
Deliverable: Operational registry accessible via UN.org/carveouts within 12 months.
Step 4 — Enable Secure Humanitarian Finance Channels
Lead: IMF + World Bank (with SWIFT and major banks)
Supporting: UNDP Finance for Development Office, central banks of neutral states (e.g., Switzerland, UAE)
- Pilot Humanitarian Transaction Corridors (HTC) — licensed, legally protected banking rails for aid flows.
- Draft guidance ensuring that humanitarian transfers are immune from secondary sanctions if verified.
- Train compliance officers in major financial institutions.
Deliverable: Operational HTC pilot corridors in 3 sanctioned regions (e.g., Syria, Afghanistan, Sudan).
Step 5 — Monitor, Report, and Adjust
Lead: Joint OCHA–PBC Standing Panel on Humanitarian Access
Supporting: UN Sanctions Committees, ECOSOC, academic partners (e.g., Geneva Graduate Institute)
- Collect quarterly data from NGOs and banks on blocked or delayed humanitarian flows.
- Issue annual “Carveout Compliance Scorecard” rating each sanctions regime’s humanitarian performance.
- Recommend technical or procedural amendments to the Security Council and GA.
Deliverable: Public annual report and live scorecard integrated with the Global Registry.
Coordination Logic
- Secretariat: OCHA Policy Branch in Geneva (light coordination hub).
- Reporting line: to ECOSOC and GA Humanitarian Affairs Segment.
- Civil society engagement: NGOs via Global Humanitarian Policy Forum.
Progress Tracker
⬜ Not Yet Initiated — Concept endorsed in principle by The Spirit of Dag; awaiting partner confirmation.
⬜ Not Yet Initiated — Preliminary outreach plan drafted; formal diplomatic approach pending.
⬜ Not Yet Initiated — Technical design under discussion; awaiting data governance partners.
⬜ Not Yet Initiated — Policy concept reviewed; operational pilot to be defined with financial institutions.
⬜ Not Yet Initiated — Standing panel framework drafted; activation linked to Step 1 launch.
Status: Conceptual phase only — implementation partners and formal launch pending.
Last updated: November 2025.
