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INSIGHT: FATF Compliance with UN Security Council Resolution 2664 (2022): Humanitarian Exemptions to Sanctions Regimes

By Andrew Dalip, Jr for AMLi

On December 9, 2022, the UN Security Council adopted Resolution 2664[i], implementing exceptions to sanctions regimes, long called for by the international aid community.

Operative Paragraph 1 creates general exemptions to most existing UN asset freezing regimes, allowing for  the provision, processing or payment of funds, other financial assets, or economic resources, or the provision of goods and services necessary to ensure the timely delivery of humanitarian assistance or to support other activities that support basic human needs by the United Nations, its subsidiary bodies, specialised agencies, and other international organisations and NGOs with a formalised relationship with the UN, together with certain extensions of their respective networks.

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