UNSCR 2664 (2022)

United Nations Security Council Resolution 2664 (2022) creates a standing humanitarian exemption to asset freezes imposed by the Security Council and its sanctions committees. Adopted on 9 December 2022 under Chapter VII, it permits specified funds, economic resources, goods and services necessary for timely humanitarian assistance or activities supporting basic human needs. It does not create a general exemption from every UN sanction or every autonomous national measure.

Scope

Operative paragraph 1 covers the provision, processing or payment of funds, other financial assets or economic resources, and the provision of goods and services necessary for covered humanitarian activity. Eligible providers include the United Nations and specified related bodies, humanitarian organisations having observer status at the General Assembly, the International Committee of the Red Cross, the International Federation of Red Cross and Red Crescent Societies, certain non-governmental organisations participating in UN humanitarian response plans, and their employees, grantees, subsidiaries and implementing partners under the text's conditions.

The resolution applies to UN asset freezes. It does not by itself disapply arms embargoes, travel bans, commodity controls, domestic counter-terrorism law or autonomous sanctions outside the UN measure. National implementation and the precise payment chain remain relevant.

For the 1267, 1989 and 2253 ISIL and Al-Qaida regime, Resolution 2664 initially applied the exemption for two years. Resolution 2761, adopted unanimously on 6 December 2024, decided that it would continue to apply. This removed the immediate sunset for that regime while retaining monitoring and reporting.

Implementation and limits

The United States issued general licences in December 2022 to align specified domestic programmes with the resolution. Other jurisdictions implemented the exemption through their own legal instruments. Those instruments may differ in programme scope and wording, so the UN resolution alone is not a complete transaction-level compliance source.

Resolution 2664 changes the legal presumption within covered UN asset freezes. It reduces the need to seek case-specific permission for qualifying activity. It cannot compel a bank, insurer or supplier to participate. De-risking can persist because institutions assess autonomous sanctions, counter-terrorism exposure, correspondent access, fraud, documentation and operational cost.

Effectiveness should be measured through payment success, cost, delay, programme continuity and residual refusal, not merely formal enactment. Safeguards and reporting are also part of the design because diversion risk and humanitarian access must be managed together.

Transaction analysis

A user should first identify the applicable UN asset freeze, then establish whether the provider and activity fall within paragraph 1, and finally check the implementing law in every relevant jurisdiction. Banks and suppliers may request evidence connecting the payment, goods or service to the humanitarian programme. Record-keeping and screening can remain necessary even where prior authorisation is not.

The exemption protects qualifying activity from the covered freeze. It does not immunise fraud, diversion or transactions outside its scope. Nor does it decide whether an autonomous designation, export control or counter-terrorism prohibition applies. Those boundaries explain why legal reform can improve access without eliminating every payment failure.

See also

Humanitarian exemptions and general licences · Humanitarian cost of sanctions · UNSCR 1267 (1999) · Afghanistan central bank reserve freeze (2021-present) · Over-compliance (de-risking) · Asset freeze

Sources

1. United Nations Security Council, Resolution 2664 (2022)), 9 December 2022.
2. United Nations Security Council, Resolution 2761 (2024)), 6 December 2024.
3. United Nations, meeting coverage for Resolution 2761, 6 December 2024.
4. United States Department of the Treasury, Treasury issues humanitarian general licences, 20 December 2022.