Sanctions In Order Research Articles

DESTRUCTIVE FACTORS OF ECONOMIC DEVELOPMENT AND WAYS TO OVERCOME THEM

Starting from 2022, the Russian national economy has been developing in difficult geopolitical and geo-economic conditions created by unfriendly states through the introduction of unprecedented economic sanctions in order to influence decisions made by the Russian political system. Purpose of the study: to determine the main exogenous and endogenous destructive factors that have a negative impact on the development of the national economy in the conditions of aggressive anti-­Russian policies pursued by the states of the “Western Coalition”, and ways to overcome them. Based on the analysis of scientific literature and statistical data, the study concluded that it is necessary to transform the spiritual, ideological and political subsystems of the institutional matrix, aimed at creating the necessary conditions for overcoming, first of all, internal destructive factors, developing competition, reducing the level of oligopoly, and developing a favorable investment environment. climate, human capital, outflow of highly qualified personnel from the Russian economy. Directions for transformation of the spiritual-­ideological and political subsystems of the institutional matrix of Russian society are proposed.

Corrective Justice For Medical Personnel Who Violate The Law: Where Is The Professional Organizations Involvement?

The provision of criminal sanctions for medical personnel who violate the law in the form of gross negligence creates legal uncertainty apart from the unclear definition of serious negligence and does not involve the role of professional medical professional organizations in determining criminal witnesses for medical personnel. This study aims to formulate aspects of corrective justice for medical personnel who violate the law, especially in the realm of criminal law. This research is a normative legal research with a concept and statutory approach. The results of the study confirm that the criminal responsibility of medical personnel requires the role of the professional organization of the medical personnel concerned. This is because the assessment of the professional organization of medical personnel is important as a form of guaranteeing justice and legal certainty for medical personnel. Corrective justice-based medical personnel accountability orientation can actually be carried out by involving the roles and recommendations of medical professional organizations. In addition, health law reform is also needed by formulating criminal sanctions for medical personnel based on ultimum remidium, namely utilizing non-prison criminal sanctions in order to achieve justice for medical personnel

Confiscation of Russian Assets for the Restoration of Ukraine: Legal Problems of Implementation

The article is devoted to the problem of creating and applying legal mechanisms for blocking and confiscating Russian assets in order to use them for the restoration of Ukraine, which suffered from Russian aggression. The subject matter of the study is the analysis of international legal norms, national law, international and national judicial practice. The purpose of the article is to study and assess the legal possibilities of compensation for damages caused by Russian aggression against Ukraine. The research methodology involves an analysis of the rules of public international law, international humanitarian law and international criminal law, which the states that have imposed anti-Russian sanctions may rely on when seeking mechanisms for confiscation of Russian assets under sanctions in order to satisfy Ukraine's claims for reparations against Russia. Achieving the objectives of the study also involves an analysis of international and national law on the issue of foreign sovereign immunity in the context of the possibility of confiscation of assets of the Russian Central Bank. The author examines the issue of freezing (blocking) of assets of persons under the jurisdiction of the countries initiating anti-Russian sanctions. The author proves that these actions are a widely used policy tool of the United States, the European Union and other states which seek to punish the government of a particular country in this way. As part of the blockade, assets may be held until the country that violates international law changes its policy. In the case of Russian aggression, the United States and other countries that have frozen Russian assets may refuse to return them as a countermeasure until Moscow not only stops its aggression against Ukraine but also pays reparations to Ukraine. It is established that the general trend (albeit with some exceptions) of the last two decades has been to strengthen the immunity from enforcement of foreign central banks' property, which is in line with the approach adopted in the UN Convention on Jurisdictional Immunities of States and Their Property. The author considers the possibility of creating legal mechanisms for the confiscation of Russian assets frozen by Western countries and a number of other states, both at the international and national levels. Based on the study, the author formulates conclusions regarding the existence of legal (both at the level of international and national law) and political (primarily, the fear of retaliatory sanctions, and most importantly, the possibility of withdrawal of assets of foreign investors and central banks of individual states from the United States) obstacles to the confiscation of Russian assets.

Challenges and Prospects of Developing Industrial Sector in Russia in Conditions of Economic Sanctions

The article describes the research dealing with trends formed in Russian industry in conditions of sanctions. Based on results of analyzing business activity of industrial enterprises factors were ranged, which limit production growth in organizations of manufacturing and mining sectors. The author revealed the impact of economic situation uncertainty on behavior of economic entities, development strategy, finance resources distribution, the level of investment activity of enterprises, as well as on the structure of finance sources of investment. In the structure of factors limiting production growth special attention was paid on home demand insufficiency, which was thoroughly studied. The author also investigated dynamics of consumer demand based on comparative assessment of retail turnover parameters, the rate of real incomes and structure of using them by the population in times of sanction introduction in 2014, 2015 and 2022. The article provides figures of the level of import-dependence in certain industries and results of pursuing policy of import-substitution. Typical problems of sectoral manufacture were identified by using the example of light industry. Distribution of entrepreneurs by fields of economic activity was analyzed and comparative analysis of sectoral structure of manufacturing enterprises in Russia and overseas countries was carried out. The author came to the conclusion that in conditions of economic sanctions in order to eliminate disproportion in industry Russia shall intensify state regulating functions and develop the system of macro-economic planning based on inter-sectoral balance.

Impact of economic sanctions on russian consumers

The formation of a new geopolitical order and, as a consequence, changes in economic contexts, presupposes the transformation of consumer behavior. In connection with this, many problems arise, both managerial and marketing in nature. In the situation of import substitution, there is a need to study changes in the structure of consumption. A study of consumers was conducted to assess the readiness to purchase domestic substitute goods. The purpose of the work is to identify the degree of influence of sanctions on Russian consumers and to assess the readiness to purchase domestic substitute goods. The study was conducted by the method of questionnaire survey on the territory of the Kostroma region. The study involved consumers from 18 to 50 years old, belonging to diff erent social groups both in terms of income and occupation. The following has been established: the shortage of goods in general is not felt by consumers, the opinions of consumers regarding the preservation of loyalty and commitment to foreign goods are divided equally, while a certain part would prefer to change preferences in favor of a similar domestic product, a positive or neutral attitude of consumers to domestic goods and services prevails, the vast majority of respondents consider domestically produced goods to be competitive. In general, the results of the study showed that consumers in the Russian market will have to slightly change their behavior, adjusting it to the effect of sanctions in order to meet existing needs.

The European leniency policy as a mechanism for protecting the rights and legitimate interests of bona fide entrepreneurs in the context of the provisions of the status of a candidate country for the accession of the Republic of Moldova to the European Union

The economic development of a state is impossible without ensuring a favorable investment climate, without ensuring non-discriminatory conditions for conducting business, including by ensuring fair competition between entrepreneurs and commercial companies.The Association Agreement between the Republic of Moldova and the EU states that "The Parties recognize the importance of free and undistorted competition in their commercial relations. The parties recognize that anti-competitive business practices are likely to distort the proper functioning of markets and reduce the benefits of trade liberalization." Starting from the assumed obligations, including the requirements regarding the harmonization of national legislation, in 2012 the parliament of the Republic of Moldova elaborated and adopted the new competition law no. 183/2012, the normative act invoked being, at that stage, an absolutely innovative one, succeeding a series of previous normative acts intended to regulate relations in the field of competition. The provisions of the analyzed law establish new approaches and attitudes, including principles, procedures and mechanisms, taking over the provisions of articles 101-106 of the Treaty on the Functioning of the European Union (TFEU). The law establishes the legal framework for the protection of competition, including the prevention and countering of anti-competitive practices and unfair competition, the realization of economic concentrations on the market, establishes the legal framework regarding the activity and competence of the Competition Council and the responsibility for the violation of the legislation in the field of competition. The main purpose of competition policies is to prevent companies from committing anti-competitive acts. Following this objective, most of the member states of the European Union have allocated powers to the national competition authorities/agencies in order to achieve two main objectives: ensuring the dissuasive effect of sanctions in order to prevent the commission of anti-competitive acts and taking the necessary measures in order to stop them. Our legislator took over the same positive practices adopted at the EU level and in the Competition Law regulated Leniency in art. 84. The article is dedicated to the analysis of the main provisions aimed at the leniency policy applicable in the Republic of Moldova, revealing the essence of this institution, the author also coming with some conclusions derived from the analysis of the national anti-competitive and criminal legislation.

Analisis Disiplin Kerja pada PT. X Gresik

The purpose of this research is useful in identifying causes and solutions to employee discipline applied in daily work activities. This study processes data from respondents and informants who were asked for information or extracted data. The data processed from the research object is an indicator of employee work discipline with a qualitative descriptive method. Collection techniques with interviews, observation and collection of documentation. The data is analyzed against the problems encountered. The research results obtained from all indicators that affect discipline have been carried out well, but leaders need to improve in giving appreciation. Other factors that cause employees to be late for work are overtime activities and work environment or congested road access. The solution that can be done is by carrying out direct supervision or by utilizing technology (systems) that can monitor employee activities from the daily reports that employees work on. Conditions must be created in a comfortable work environment by improving road access, transferring attendance media (fingerprints) near the parking area. Continuous work evaluation is the provision of direction and motivation and the provision of periodic sanctions in order to achieve a higher level of discipline and to have a positive impact on the company.

Economic development and the rise of Russia under sanctions

Comparative study of the macroeconomical development of Russia during the sanctions period through comparative and statistical analysis of the dynamics of the main macro indicators, which allows analyzing the economic development of a country under sanctions and getting a new idea of how the country functions in this changing reality. The modern world economy is going through a period of sanctions wars between countries, which are conducted openly or secretly with the help of international institutions. In this regard, it is becoming increasingly useful to analyze the economic development of countries under sanctions in order to gain a new understanding of how countries function in this changing reality. Comparative study of the macroeconomical development of Russia during the sanctions period by means of comparative and statistical analysis of the dynamics of the main macro indicators, including growth rates and the value of GDP for the base period, consumer spending, gross capital accumulation, exports, imports, etc. Theoretically, the description of sanctions as a tool for harming economic development is chosen as a methodology for international comparisons and analysis of statistical data that can be used to assess various sanctions against economic development. The analysis of empirical data does not reveal a clear connection between the dynamics of indicators and the imposition of sanctions, which is confirmed by an empirical analysis of the available data. Countries are forced to achieve their economic development goals in conditions of severe restrictions that do not restrain other countries. This fact adds to the specifics of the current global market and the ongoing market competition.

Unilateral Sanctions in the Context of Modern International Law

The author discusses the modern international legal framework governing the application of sanctions. The author focuses on the following issues: international and regional sanctions in the context of the UN Charter, restrictions on sanctions regimes, sanctions in humanitarian law, the legitimacy of unilateral economic sanctions. The methodological base of this work is a systematic approach, which allows to consider sanctions as part of the modern international legal system. As a result of the study, it was revealed that within the framework of the existing international legal system, only the UN Security Council is authorized to impose sanctions in order to ensure global peace and security. The resolutions of the UN Security Council on the issue of the application of restrictive measures are dominant in comparison with the decisions of other international bodies and the obligations of member countries under international treaties. The legitimacy of applying regional sanctions is limited by the statutes of regional organizations. The novelty of the study lies in a comprehensive consideration of the reasons why unilateral sanctions are a violation of international law. Unilateral economic restrictions violate the free trade regime of the WTO and the principle of non-discrimination that underpins the GATT. They represent a violation of the fundamental principles of sovereign equality, as well as the principle of non-interference in the internal affairs of other states. As a result of the application of economic sanctions by certain states, extraterritorial jurisdiction is manifested, which creates a dangerous precedent for international law.

Analisis Yuridis Pencabutan Hak-Hak Politik Pelaku Tindak Pidana Korupsi (Studi Putusan Mahkamah Agung RI Nomor 113 K/PID.SUS/2020)

Eradicating the crime of corruption must apply strict sanctions in order to provide a deterrent effect for corruptors, as well as being expected to reduce anyone from committing corruption. One of the latest breakthroughs is to apply additional criminal sanctions for revocation of certain rights. The formulation of the problem in this thesis is how the legal arrangements for the revocation of political rights against perpetrators of criminal acts of corruption, how criminal responsibility for perpetrators of criminal acts of corruption, how the legal considerations of judges on the revocation of political rights against perpetrators of criminal acts of corruption. The research method used is descriptive analysis that leads to normative juridical legal research, namely research conducted by referring to legal norms, namely researching library materials or secondary materials. Secondary data by processing data from primary legal materials, secondary legal materials and tertiary legal materials. The legal regulation on the revocation of political rights in the form of the right to be elected in public office is the implementation of the application of criminal sanctions that are extraordinary enforcement as regulated in Article 17 of the Law of the Republic of Indonesia Number 31 of 1999 in conjunction with the Law of the Republic of Indonesia Number 20 of 2001 concerning Eradication Corruption crimes may be subject to additional penalties as referred to in Article 18 paragraph (1) letter d and Article 10 letter b number 1 of the Criminal Code concerning additional penalties. The results of the study indicate that the judge's legal considerations for the revocation of political rights against perpetrators of criminal acts of corruption are criminal acts committed cannot be a good example. At the end of its decision, the Panel of Judges imposed an additional penalty on the Defendant in the form of revocation of the right to be elected in public office for 3 (three) years after the Defendant had finished serving his main sentence.

SANCTIONS AS A TOOL TO ACHIEVE COMPLIANCE WITH INTERNATIONAL LAW: SOME ISSUES OF NATIONAL IMPLEMENTATION AND ENFORCEMENT

The article is dedicated to sanctions as a tool for enforcing international legal obligations. In particular, some issues of their implementation at the national level are considered. The author analyzes the recent practice and legislation of the US, the EU, Canada and Ukraine. The choice of these actors is explained by their active participation in sanctions imposed on the Russian Federation in relation to its invasion of Ukraine. The main purpose of the study is to make a comparative analysis of national regulations in order to make recommendations for the improvement of the Law of Ukraine «On Sanctions» under which the sanctions on the Russian Federation and their residents are imposed. The publication considers such questions as the definition of sanctions or restrictive measures as they are often named, the grounds of their adoption, their types and enforcement. The last aspect is of great importance due to the fact that private companies often try to evade sanctions because for them sanctions mean restriction of their economic activities and, consequently, financial loss. In this regard the enforcement practice of the US is very useful and can be considered to be an example to follow for Ukraine and even for the EU. At the same time a very broad basis for US sanction imposition poses the question of their lawfulness both through the prism of international economic law and international human rights law. In this connection it is suggested that Ukraine should have a reasonable and more logical approach to the formulation of grounds for sanctions adoption that would be more consistent with the legal positions of other states applying sanctions in order to enforce international law.

The doctrine of environmental law: theoretical and methodological problems

The problem of studying the goals, objectives and legal mechanisms for the implementation of the Environmental Doctrine of the Russian Federation and the development of the doctrine of environmental law in the absence of a clear systematization and interconnection of a set of strategic planning documents is very relevant.The article summarizes and analyzes the main provisions of the Environmental Doctrine of Russia. The authors show that economic globalization significantly changes the nature of environmental management. Many environmental phenomena and related social relations are of a national, international nature.The authors of the article investigated the issues of strategic understanding of international and national environmental policy. The necessity of forming the doctrine of environmental law is shown.The authors believe that the current trends in the development of international relations and the national characteristics of Russia, its competitive advantages, as well as the challenges it faces internally and externally, require the development and implementation of a new environmental policy, its transformation into one of the national and foreign policy priorities. The authors substantiate the necessity and possibility of revising the current environmental and legal national regulation. The ideological and organizational-legal features of the preparation of a new environmental doctrine and the doctrine of environmental law are shown.The article is aimed at the development of ecological and legal mechanisms of environmental protection in the conditions of economic sanctions in order to develop a balanced state environmental policy in the new economic and political conditions of socio-economic development of Russia.

Regulation of Sanctions in Increasing Supervision of the Food and Drug Supervisory Agency (BPOM) Against the Circulation of Food and Drugs Containing Hazardous Materials

Processed food products circulating in the market do not all provide guarantees of quality and safety for consumers. The number of cases that afflict consumers due to consuming processed food products that do not meet the specified quality standards, for example the case of packaged milk containing melamine, non-halal adjinomoto cooking spices, candy containing addictive substances, and others. The problems discussed in writing this article are the form of increased supervision of the Food and Drug Supervisory Agency (BPOM) on the circulation of food and drugs containing hazardous materials and the efforts of the Food and Drug Supervisory Agency regarding the circulation of food containing hazardous materials. The research method used in the provisions governing the existence of sanctions in order to increase effective supervision for perpetrators who violate these rules. So it is hoped that strict sanctions for business actors who violate in the context of writing articles are normative legal research, in the form of research by examining laws and regulations that are related to legal problems that occur. The results of the study form ways to improve supervision carried out by BPOM by indirectly forming an integrated food supervision network with other agencies such as the agriculture department, the trade department, which collaborate in particular to conduct a supervision team on the circulation of food and drugs containing hazardous materials. Therefore, BPOM must carry out its duties and functions collectively to prevent business actors from committing fraud by using materials containing hazardous substances. Then the efforts made by the Food and Drug Supervisory Agency related to the distribution of food containing hazardous materials, namely preventive and repressive efforts. As for suggestions from the author, namely the Food and Drug Supervisory Agency to carry out intensive and equitable supervision to minimize the circulation of food containing hazardous materials that endanger public health and it is recommended to take preventive and repressive protection efforts.

Promoting Sustainable Timber Harvesting Through National Forestry Act 1984

This study explored respondents’ perceptions regarding the adequacy of heavy, moderate and light punishment associated with offences under the National Forestry Act 1984 (Act 313) as the primary forestry law enforced in Peninsular Malaysia. It also examined the role of supervision and inspection in controlling illegal logging and forest offences as well as the adequacy of law provisions concerning inspections in logging area, in transit and in manufacturing premises. Questionnaires were distributed to seek responses from related stakeholders of forestry enforcement agencies. The output of data analysis indicated that an effective law should carry adequate sanctions in order to have the deterrence effect, scare prospective offenders and discourage repeated commission of the convicted offences. The outcomes of the survey revealed that as a whole, Act 313 was effective to control illegal logging. In the context of punishment, heavy punishment associated with serious offences was rated as effective compared to moderate and light punishment. Findings on specific aspects of legal provisions as identified in this study may provide awareness for relevant agencies for revisiting policies towards achieving sustainable timber harvesting.

Working Paper 42: From sanctions to confiscation while upholding the rule of law

Written in the light of Russia's war of aggression in Ukraine, the Working Paper explores whether it is justifiable to confiscate assets frozen under financial sanctions in order to redirect them to the victims of state aggression. 
 The paper first explores the concept of sanctions and financial sanctions (asset freezes) and what they mean in practice.
 Using the example of Canada, which has introduced a legislative mechanism for this purpose, the paper analyses whether states should be able to confiscate sanctioned assets purely on the basis that they have been sanctioned.
 It then looks at more established measures that states could adopt and apply to target sanctioned assets, including:
 
 Traditional conviction based confiscation measures, including 'extended confiscation' mechanisms
 Non-conviction based confiscation (forfeiture) measures
 Unexplained wealth laws
 
 The paper recommends ways to maximise the effectiveness of these alternative avenues for recovering assets, which are much less controversial and can arguably be applied without infringing on legal rights. 
 Opting for mechanisms that abide by established legal rights will not only significantly increase the chance of recovering assets without subsequent legal challenges. It will also ensure that the very reason for targeting the assets in the first place – namely to seek justice and compensation for acts of aggression – is not undermined through the erosion of the rule of law.

Fulfilling the Right of Education during Covid19 Pandemic Period: A Comparative Study

The right of education for citizens has been fulfilled diversely following the government policies. This study aimed to emphasize the importance of the education right and the imposition of criminal sanctions in order to protect the right of education during the Covid-19 Pandemic particularly in Indonesia, Japan and Australia. Normative juridical research methods described that government policies as outlined in the legislation constantly followed by criminal sanctions. The concept of education right was understood in a different way during the Covid-19 pandemic, as one of the derogable-right or adapted human right. For its fulfillment, some education right uses criminal sanctions as a primum remidium, an ultimum remidium, or does not impose criminal sanctions at all. The right of education still reman as a very important human right even during the pandemic period

Development of countries under sanctions: Iran and Russia

Relevance. The modern world economy is going through a period of ‘sanctions wars’ between countries waged openly or covertly through international institutions, with Russia and Iran serving as vivid examples of the first and second cases, respectively. In this connection, it is increasingly useful to analyze the economic development of countries under sanctions in order to gain new insights into how countries function in this changing reality. Research objective. The study aims to comparatively examine the macroeconomic development of Iran and Russia during the sanctions period through a comparative and statistical dynamics analysis of the main macro indicators, including the growth rate and value of base-period GDP, consumption expenditures, gross capital formation, export, import, etc. In theoretical terms, the description of sanctions as an instrument for harming economic development is chosen as a secondary aim in this work. Data and methods. The study is based on the methodology of international comparisons and an analysis of statistical data that can be used to assess the impact of various sanctions on economic development. Results. The uncertain impact of sanctions on economic development is confirmed. The analysis of empirical data collected over a twenty-year period, reveals no clear connection between the dynamics of indicators and the imposition of sanctions (both for Iran and Russia), which is confirmed by an empirical analysis of available time series. Although in some industrial areas, difficulties were observed. In addition, with the imposition of more stringent sanctions in 2012, the Iranian economy experienced a significant decline, followed by its recovery during the adaptation period. Conclusions. A counter-sanctions policy requires the integrative cooperation of targeted countries, which opens up new frontiers of collaboration between Iran and Russia. New forms of international labor division should be created to eliminate the possibility of some countries using sanctions as an instrument against others.

The Effect of Regional Income, Leverage, Regional Property on Internet Financial Reporting Disclosure

This study aims to analyze the effect of local revenue, leverage, local government wealth on the disclosure of web-based local government financial statements. The population and sample of this study are the regional government financial reports of Central Java Province which consist of 29 districts and 6 cities for the 2015-2018 fiscal year which have been audited by the BPK. The analysis method uses a multiple regression panel data model with the Eviews 9 application. The results of this study indicate that local revenue and general allocation funds have a significant positive effect on the disclosure of web-based local government financial reports. However, the wealth of the local government in turn has a negative effect on the disclosure of web-based local government financial reports. Meanwhile, leverage has no effect on the disclosure of web-based local government financial statements. The results of this study can be used as a consideration for the government informing regulations, rewards, and sanctions in order to increase the transparency of digital financial reports.

Pengaruh Pengampunan Pajak dan Kemudahan Administrasi Pajak Terhadap Kepatuhan Wajib Pajak Orang Pribadi pada KPP Pratama Jakarta Penjaringan

Tax amnesty is a government policy program that provides an opportunity for taxpayers to pay their tax arrears without administrative sanctions in order to improve taxpayer compliance and state revenue. Given the importance of tax forgiveness programs in the implementation of government policies, especially in the implementation of self assessment system, it is interesting to examine how the implementation of tax capability is done by the Directorate General of Taxes in this case in the Tax Office Pratama Jakarta Penjaringan. In the preparation of this study, the authors use a quantitative approach, namely research that emphasizes the analysis on numerical data or numbers obtained by statistical methods and conducted on inferential research or in the framework of hypothesis testing so obtained the significance of the relationship between variables studied. The purpose of this study is to determine the implementation of tax pardons conducted by KPP Pratama Jakarta Penjaringan, ease of tax administration and changes in taxpayer compliance increase. The conclusion of research, that the implementation of tax amnesty and the ease of tax administration conducted by KPP Penjaringan in the period 2015-2017 have a strong influence on taxpayer compliance. The coefficient of determination (adjusted R2) shows the variable of Tax Amnesty (X1) and Ease of Tax Administration (X2) can explain or explain Personal Taxpayer Compliance KPP Pratama Jakarta Penjaringan (Y) of 28%. KPP is advised to improve tax administration system, service to Taxpayer, tax law enforcement and tax rate and intensive socialization to taxpayer about good tax administration knowledge.

Counterterrorism, sanctions and financial access challenges: Course corrections to safeguard humanitarian action

AbstractThis article provides an overview of the impact of United Nations (UN) sanctions and counterterrorism (CT) measures on humanitarian action. The mandatory requirements of UN Security Council Resolutions 1267 and 1373 on member States to prohibit the provision of “funds, financial assets or economic resources” to terrorists complicates the work of humanitarian actors delivering assistance in areas where groups designated under the 1267 regime control territory. After explaining the impact of sanctions and CT measures on humanitarian actors, the article explores three primary sets of challenges encountered by such actors: (1) lack of clarity and adequate legal protection for carrying out humanitarian activities in countries subject to sanctions or areas in which designated entities operate; (2) financial access difficulties or de-risking by financial institutions limiting the ability of non-profit organizations (NPOs) to transfer funds to higher-risk jurisdictions due to banks’ risk aversion or fear of regulatory scrutiny of such transactions; and (3) conditions placed in funding contracts by donors effectively offloading CT and sanctions risks onto beneficiaries. The article analyzes experience with UN humanitarian carve-outs (exceptions as employed in the Somalia sanctions regime and case-by-case exemptions utilized in the North Korea regime), explaining why exceptions are the optimal solution for humanitarian actors. New data are presented indicating that the scope and scale of financial access difficulties experienced by NPOs have grown. Financial institutions, concerned about regulatory requirements to counter terrorism financing, are increasingly reluctant to provide banking services to NPOs working in highly sanctioned jurisdictions, and the resulting de-risking by banks results in significant problems for humanitarian organizations needing to move funds abroad. Additionally, contractual conditions related to CT and sanctions compliance are routinely employed by donors, resulting in an offloading of risk onto recipients without appropriate clarity and guidance from donors. Numerous initiatives in recent years have called attention to the challenges that humanitarians face: stakeholder dialogues, high-level meetings and other discussion fora promote broader understanding among participants and acknowledgement of the impacts that these polices have on humanitarian action. UN action to renew the 1267 regime's mandate and the consideration of a humanitarian carve-out in Afghanistan in the aftermath of the Taliban's takeover represent opportunities to reform sanctions in order to better protect humanitarian action. Recommendations are presented for each of the three sets of challenges, with an urgent call for the Security Council to embrace the opportunity for reform and more effectively balance the equally critical objectives of countering terrorism and safeguarding humanitarian action.