The impact of bank de-risking on the humanitarian response to the Syrian crisis

The Syrian crisis is a complex environment for aid agencies wishing to move funds for humanitarian purposes into the country, or through neighbouring states supporting regional humanitarian efforts. The combination of counter-terrorist financing (CTF) legislation and international sanctions have made it very difficult for humanitarian organisations to move and access funds. The largest Syrian banks are under sanctions by the United States, the European Union (EU) and other states, and the banking system in areas outside of government control has largely been destroyed.
Syria’s immediate neighbours (Turkey, Lebanon and Jordan) have challenging regulatory arrangements and financial systems; Turkey, for example, has closed down several non-governmental organisations (NGOs) and substantially increased the bureaucratic processes to which humanitarian organisations are subject.