Exceptions to sanctions

Sanctions need to be tailored to target the right people and organisations, while sparing the general population as much as possible. For this reason, sanctions regimes always include exceptions.

For example:

  • in the case of someone facing a visa ban, an exception might be granted for urgent humanitarian reasons or because the person in question is a guest of an international organisation in a certain country;
  • exceptions for the delivery and funding of humanitarian goods like food and medicine;
  • an exception to a sector-based import/export ban by means of an order, which ensures that existing contracts (open-ended or fixed term) can still be honoured;
  • a special permit may be issued to a person or company on the sanctions list, enabling them to comply with pre-existing obligations. For example, paying for delivered goods or paying damages;
  • the partial lifting of an arms embargo to allow the importation of non-lethal equipment or material for humanitarian use, defensive objectives, crisis control operations by the UN or EU or de-mining operations;
  • exceptions that are necessary for diplomatic business. This allows for payments to embassies and international organisations.