On August 13, 2021, the EU Commission published an additional Guidance Note to expand upon the ways that humanitarian aid related to COVID-19 assistance can be provided in countries subject to counter-terrorism sanctions. The new Note replaces Commission Notice C(2020) 7983 final, that was adopted on November 16, 2020, and builds upon existing chapters on Syria, Iran, Venezuela and Nicaragua. The purpose of the Note is to provide practical guidance to all EU Member States that are called upon to advise humanitarian activities at a domestic level and provide clarity to both public and private operators interested in providing aid to combat the COVID-19 pandemic, particularly when encountering issues related to EU counter-terrorism sanctions, including Council Regulation (EC) No 881/2002 of May 27, 2002; Council Regulation (EU) 2016/1686 of September 20, 2016; and Council Regulation (EC) No 2580/2001 of December 27, 2001.
While there are almost 40 separate sanctions regimes in place in the EU, the Commission prefers that all sanctions programs be applied in a manner that reduces negative consequences for civilian populations and considers the needs of humanitarian operators, especially medical vaccines and therapeutics used to treat COVID-19.
European Commission Press Release | European Commission Guidance Note