Executive summary and main findings of the research
NGOs working on Syria and/ or operating within the country have been confronted with rising obstacles since 2014 in their dealings with banks and financial institutions at different levels. This has been ongoing until the current time. Any mention of Syria is a red flag for banks and final institutions.
The report follows the different phases of process involved in payment mechanisms and financial operations faced by NGOs and INGOs, from opening the bank account, passing through transfer operations, to the consequences of these problems. The research provides a global analysis of the financial operations and challenges faced by NGOs (Syrian and non-Syrian), INGOs and state and EU agencies starting from European countries to those neighboring Syria (Turkey, Lebanon and Kurdistan Iraq) as well as Syria itself.
Alongside these challenges in the financial circuit, the report analyses key problems encountered by humanitarian organizations posed by the various sanctions regimes in place and particularly those imposed by the US and their extraterritorial nature.
The research notes that NGOs and INGOs working on and / or operating in Syria have faced ever-increasing difficulties and some have had to cancel projects because they could not keep up with the paperwork required by donors. Unfortunately, despite various global initiatives and conference that have taken place in recent years between various actors (NGOs and INGOs, states officials, and banking employees) to improve and facilitate the financial operations and transfers of NGOs working on or in Syria, there has been no significant progress made to date; frequently quite the opposite.
While larger NGOs and INGOs can sustain some of the difficulties encountered in the obstacles and challenges posed by delays and blocking of financial operations (often because of the larger flows of money involved and larger compliance teams), more modest and smaller entities have suffered more. This said, this situation has not lessened the transfer of risks to the Syrian NGOs operating in the field in Syria or in neighbouring countries; quite on the opposite. As such, smaller humanitarian organizations are disproportionally affected by bank de-risking processes.
In conclusion, better provision of guidance and support by sanctions-enforcing bodies is welcome, but clearly not enough to bypass the structural problems faced by humanitarian NGOs and INGOs operating in Syria or in neighbouring countries, or more generally in conflict zones. The challenges faced by Humanitarian NGOs and INGOs are not simply obstacles to try to overcome on a case by case basis, but are structural in nature and rooted in the financial system and the current international sanctions framework.