Financial Crime World

Risk Management Principles Guide for Humanitarian Funds into Syria and Similar High-Risk Jurisdictions

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Key Considerations for Humanitarian Response in Syria

Humanitarian agencies operate in various modalities, including:

  • Regular programming from registered organizations: Established channels for delivering humanitarian aid to those in need.
  • Cross-line operations: Activities conducted within areas inaccessible or difficult to access by established means.
  • Cross-border operations: Aid delivered directly into specific areas of conflict or crisis.

Due Diligence and Risk-Mitigation Standards

Humanitarian actors are committed to following international standards for:

  • Baseline monitoring: Regular assessments to identify potential risks and vulnerabilities.
  • Due diligence: Thorough investigations to ensure compliance with regulations and minimize risk exposure.
  • Risk-mitigation strategies: Implementing measures to prevent or reduce the impact of identified risks.

Financial Services for Humanitarian Activities

Humanitarian organizations require access to a range of financial services, including:

  • Correspondent banking: Facilitating international transactions and managing financial relationships with other banks.
  • Currency services: Managing exchange rates, currency fluctuations, and related risks.
  • Sale or purchase of gold, precious metals, and diamonds: Ensuring compliance with regulations and minimizing risk exposure in high-value transactions.

Structuring Humanitarian Activities for Compliance

The guide emphasizes the challenges faced by financial institutions and humanitarian aid deliverers in:

  • Avoiding sanctions violations: Ensuring that activities comply with international sanctions frameworks.
  • Compliance with local regulations: Adhering to laws and regulations of the host country (Syria) and other relevant jurisdictions.
  • Coordinating with Syrian authorities: Maintaining open communication and cooperation with relevant authorities to ensure compliance and avoid misunderstandings.

The guide provides essential information for organizations involved in humanitarian efforts in Syria, highlighting the complexities of navigating regulatory and sanctions frameworks while ensuring the delivery of critical aid.