Resolution 2664, adopted by the UN Security Council on December 9, 2022, was a landmark resolution that created a clear and well-defined humanitarian carve-out for UN sanctions. The application of the carve-out to the 1267 ISIL/al-Qaida regime was particularly important given the far-reaching impact of that regime. It applies across multiple countries, including some of the world’s most challenging humanitarian contexts.

This paper examines how Resolution 2664 has established a humanitarian carve-out within UN sanctions regimes and its impact on facilitating humanitarian access to financial services. It also analyzes the limitations the resolution imposes on asset-freeze measures and specific humanitarian organizations, as well as the challenges of extending the carve-out for the 1267 ISIL/al-Qaida regime beyond its expiration in December 2024.

In order to maintain the positive impact on humanitarian operations of the resolution so far, including in situations impacted by the 1267 ISIL/al-Qaida regime, and to realize the full potential of Resolution 2664 in safeguarding humanitarian action, this paper offers the following recommendations:

• Security Council members should decide a standing application of the humanitarian carve-out for the 1267 ISIL/al-Qaida sanctions regime in December 2024.
• Humanitarian actors should continue to provide member states with evidence of the positive humanitarian impact of Resolution 2664.
• Humanitarian actors should continue to share information with member states and donors about their due-diligence and risk-mitigation practices and any instances of incidental benefits going to listed individuals or entities.
• All stakeholders should ensure that discussions around Resolution 2664 and the carve-out for the 1267 ISIL/al-Qaida regime are fact- and evidence-based.
• Member states should fully implement Resolution 2664 in a harmonized manner and pursue efforts to socialize and operationalize it.
• All stakeholders should pursue and strengthen cross-sector engagement.