06/30/2020 Washington, D.C. (International Christian Concern) – In a recent tweet, Ambassador Sam Brownback highlighted the important role of humanitarian NGOs in addressing the world refugee crisis. Today, non-governmental humanitarian assistance forms a critical piece of the world’s humanitarian response apparatus. This has become increasingly true in recent decades as private humanitarian assistance has gone from roughly equal to government assistance to many times its size.
Policymakers in Washington, D.C. need to recognize the importance of private humanitarian assistance and take care that it not be inadvertently stymied as foreign policy is crafted and implemented.
According to the Hudson Institute, member countries of the Organization for Economic Cooperation and Development (OECD) donated a combined $137 billion to the developing world in 2014. Non-OECD governments gave another $10 billion, for a combined $147 billion in government aid in 2014, the last year analyzed in the Hudson study. While this number helps to illustrate the world governments’ commitment to assisting the developing world, it pales in comparison to the private aid given that same year, at $801 billion.
Though differing definitions of foreign aid make coming to an exact number difficult, the U.S. gives about $30 billion to the developing world every year. By contrast, the next biggest governmental donor gives well under $20 billion.
As substantial as the U.S. government’s support for the developing world is, private aid dwarfs it. Private philanthropy alone outsizes governmental giving by 33%, and personal remittances from the U.S. outpace government giving by 220%. Altogether, the developing world receives over $360 billion from the U.S. every year—over 90% of which is from private sources.
These facts do not trivialize the importance of government aid. The $50 million recently dedicated by the Trump administration to advancing international religious freedom is an important gesture, and will have a very real impact on individual lives all around the world. But the role that the government plays through its own assistance work must not cause policymakers to overlook the government’s role in influencing private generosity and investment.
Of primary importance in this regard is the potential for sanctions to unnecessarily hinder private humanitarian relief work. Country-level sanctions, typically designed to put pressure on a problematic government, can too easily deter private assistance even in cases where that assistance is still permitted under the terms of the sanctions.
Sanctions are designed to deter economic engagement with a targeted country. And with fines of up to $1.25 million and prison sentences of up to 20 years, U.S. sanctions carry with them a significant deterrent effect. This is by design, and much of the efficacy of sanctions lies in these strong penalties.
However valid a sanction might be, though, its potential to deter bona fide private humanitarian assistance is one that policymakers must take into consideration—especially when preventing such activity is not the intention.
Some sanctioning authorities contain exceptions for humanitarian assistance, and for others the U.S. Treasury’s Office of Foreign Assets Control issues licenses allowing humanitarian activities to continue where they would otherwise run afoul of the relevant sanctioning program. These licenses come in two forms—general and specific. General licenses create standing exceptions for whole classes of persons—often including humanitarian actors—while specific licenses only authorize a particular transaction.
While these exceptions and licenses are intended to make room for humanitarian work to continue in a sanctioned country, they are often too opaque to be useful towards that end. Whether because the exception is buried too deep within the federal code, because general licenses are subject to change without notice, or because specific licenses are too difficult to obtain, private humanitarian assistance is often unintentionally blocked.
Greater outreach to the private sector is needed, and where sanctions are not intended to stop humanitarian aid that should be made explicitly clear. The cost of even accidentally violating U.S. sanctions authorities is extremely high. Clarity around the humanitarian exceptions to those sanctions must be proportionately high if private humanitarian aid to those countries is to continue.
The ever-changing nature of foreign affairs ensures that U.S. foreign policy will remain a nuanced and complex matter for all parties involved. Care must be had that private humanitarian aid not become an unintended casualty of that complex system and proactive policies must put in place to guarantee that bona fide humanitarian assistance is not inadvertently shut down.
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