About the author(s):
Mohammad Kanfash is a doctoral researcher at the Centre for Conflict Studies, Utrecht University, and a humanitarian practitioner with 17 years of experience in the Middle East and Europe. His work bridges academic inquiry and field practice, focusing on sanctions and their consequences for conflict-affected societies.
This post forms part of phase two of the Beyond Compliance Symposium: How to Prevent Harm and Need in Conflict, hosted by the Armed Groups and International Law blog. The introductory post can be found here. The symposium invites reflection on the conceptualisation of negative everyday lived experiences of armed conflict, and legal and extra-legal strategies that can effectively address both civilian harm and humanitarian need.
Introduction
Unilateral sanctions have become the tool of choice for the United States (U.S.), the European Union, and increasingly China, to advance their interests and see their adversaries off. In parallel, the growing reliance on sanctions can also be observed in the workings of the United Nations Security Council. The exponential rise in the use of sanctions is best captured by statistics. By 2023, estimates suggested that one in four countries were under US or UN sanctions, while a year earlier, it was reported that more than 800 million people, roughly 12% of the population of the developing world, live in countries under a U.S. sanctions program.
Sanctions vary in scope, ranging from targeted travel bans on individuals to sweeping sectoral restrictions and near-total embargoes. For policy makers, sanctions are easy to impose because they can be readily justified for domestic constituencies. Often couched in the language of international norms and values, sanctions are presented as an alternative to war or a ‘middle range of policy alternatives that is stronger than diplomatic, but less coercive than military force.’ In situations where inaction is politically untenable but deeper engagement is risky, sanctions offer a seemingly logical and morally attractive solution for both governments and concerned citizens alike.
© ICRC/ May Saad (22/09/2021, V-P-SY-E-01034), Syria. Tartus Governorate, Banias. This beekeeper was deeply affected by the negative economic consequences of the conflict. Like 240 other beekeepers of the region, he received equipment from the ICRC and the Syrian Arab Red Crescent to help him increase its income. Many households depend on beekeeping in Tartus region. The sector suffers from the current crisis because of the pressure of inflation on equipment and transportation prices, and because of security issues.
Yet, this seemingly benign tool carries a darker reality. The legality and legitimacy of sanctions, unilateral regimes in particular, are increasingly called into question, including by bodies such as the UN General Assembly. Furthermore, their often negative, and occasionally disastrous, impact on the populations of targeted countries, is often dismissed and uncritically labelled as ‘unintended consequences,’ a euphemism that obscures the structural harm they inflict. Among the chief drivers of this harm is the growing phenomenon of private sector overcompliance, the central focus of this blog.
Using Syria as a case study, this blog explores how overcompliance with sanctions regimes has compounded civilian suffering in the war-torn country. It proceeds in three parts. First, it briefly examines the so-called unintended consequences of sanctions. Second, it zooms in on overcompliance and its role in amplifying these effects. Third, it turns to Syria, illustrating how overcompliance has deepened humanitarian harm and may even raise questions about violations of international humanitarian law.
Sanctions and civilian harm
That sanctions inflict harm on civilian populations is no longer contested. Examples abound. In Iraq, hundreds of thousands of civilians are believed to have suffered and died owing to the ‘unintended consequences’ of what scholars have argued to be a form of ‘genocidal’ sanctions, while in Afghanistan the impact of US sanctions on the country in less than a year was feared to be deadlier than two decades of active warfare. Likewise, in Iran and Venezuela, sanctions have been found to have negative effects on variables ranging from per capita income to poverty, inequality, mortality, and human rights.
A 2025-study published in the Lancet estimates that over half a million people die each year due to unilateral economic sanctions. This staggering figure is roughly equivalent to total deaths from wars, including civilian casualties, and is more than the annual number of battle-related casualties.
When imposed comprehensively, sanctions can be devastating for targeted societies with long-term socioeconomic consequences. Unlike the victims of physical violence, the suffering of sanctioned societies often remains obscured and buried in abstract statistics and economic indicators. This invisibility, in turn, renders their pain largely unnoticed, rarely capturing the attention or urgency that more visible forms of conflict provoke. In this sense, while sanctions are often justified as tools to uphold human rights or enforce international law, they can become chief drivers of harm in the very societies they claim to protect.
Overcompliance: When Fear Trumps Law
Among the most harmful side effects of widespread sanctions is the growing phenomenon of overcompliance by private companies and humanitarian organisations. In short, over-compliance is a form of excessive avoidance of risk, a form of excessive risk aversion. Rather than adhering strictly to the letter of the law, private actors such as banks, insurers, logistics firms, and NGOs, routinely go beyond what sanctions legally require.
This behaviour is driven less by legal obligation than by fear: fear of regulatory scrutiny, financial penalties, reputational damage, or inadvertent violations. As a result, these actors often pre-emptively avoid transactions or engagements that are, in fact, permitted under existing exemptions or humanitarian carve-outs.
Overcompliance manifests in multiple ways and is driven by a range of logics—some arguably defensible, others deeply problematic. Yet at its core, overcompliance is not a spontaneous or misguided reaction. It is, as this blog argues, a structural outcome of the deliberate outsourcing of sanctions enforcement to the private sector, particularly the financial sector, by sanctioning states, most notably the United States. Through expansive legal mandates, uncertainty, aggressive extraterritorial enforcement, and the threat of punitive penalties, these states have effectively weaponised compliance itself.
In doing so, they have transformed banks, insurers, and humanitarian intermediaries into instruments of coercion: actors who, out of fear rather than legal obligation, routinely block, delay, or withdraw from transactions that are otherwise lawful. This dynamic lies at the heart of the humanitarian fallout that sanctions regimes so often produce.
Syria: A Case Study in Sanctions Overreach
By the end of 2024, Syria had become the world’s third most sanctioned country, after Russia and Iran. US sanctions on the country have evolved into a near-total trade embargo, while the EU imposed what was then its most extensive sanctions regime. Alongside restrictions from regional and international actors, including Canada, Australia, Japan, Switzerland, Türkiye, and the UK, the combined US and EU sanctions have produced one of the ‘strictest and most complex collective regimes in recent history’ or even one of the ‘most complicated and far-reaching sanctions regimes ever imposed.’ The presence of jihadist groups, targeted by UN Security Council resolutions, has further complicated humanitarian and financial engagement.
In this environment, overcompliance has flourished. Overcompliance in Syria has severely disrupted humanitarian aid, financial flows, and essential services, compounding civilian suffering across multiple sectors.
Despite formal exemptions for humanitarian assistance, NGOs face significant barriers to accessing funds, transferring money, and procuring essential goods. Akin to other heavily sanctioned jurisdictions, banks frequently refuse to process transactions involving Syria, even when they are clearly permitted, due to fear of violating sanctions or triggering regulatory scrutiny. This has led to frozen accounts, blocked wire transfers, and the collapse of financial channels critical for aid operations. Problematically and as a result, many NGOs have scaled back or suspended activities, particularly in areas deemed high-risk due to sanctions or the presence of designated groups.
The 2023 earthquake response laid bare these failures. Humanitarian organisations faced major delays in delivering emergency relief due to banks and logistics firms refusing to process transactions, even those exempted under humanitarian carve-outs. NGOs reported blocked wire transfers and frozen accounts, with some unable to pay local staff or procure medical supplies.
Sanctions and overcompliance have also devastated food security. They have created a chilling effect on both humanitarian actors and private suppliers, leading to overcompliance and the withdrawal of critical services. This has obstructed the import of agricultural inputs, and hindered food production, among others, deepening hunger and hardship across the country.
Across sectors, the impact is clear. Throughout the conflict which broke out in 2015, but especially as of 2019, when the US imposed extra-territorial sanctions on the country, sanctions and overcompliance transformed Syria into a landscape of paralysis and misery—where aid is delayed, services are denied, and civilians bear the brunt of a system designed to punish governments but ends up punishing people.
Conclusion: From Exception to Accountability
Overcompliance is not a marginal or accidental feature of sanctions regimes: it is a systemic consequence of how these regimes are designed and enforced. Syria’s experience reveals the full weight of this dynamic: humanitarian aid obstructed, food security dismantled, and civilian life paralysed by fear-driven disengagement. While recent efforts—tri-sectoral dialogues, legal advocacy, and policy clarifications—signal growing awareness, they remain piecemeal and insufficient.
To move forward, innovation may be necessary. To address negative lived experiences of overcompliance to unilateral sanctions, the phenomenon must be addressed not just as a technical flaw but as a question and matter of accountability and complicity. When private actors, under pressure from sanctioning states, inflict harm by exceeding legal boundaries, they become potentially complicit in the suffering of protected populations. This demands a shift in how we understand responsibility under international law—not only for those who impose sanctions, but also for those who enforce them beyond the law. Ending this cycle requires more than reform. It requires reckoning—with the structures that normalise harm, and with the silence that sustains it.