Tackling Unintended Consequences of EU Sanctions: NGOs' Advocacy for Humanitarian Exceptions

Sanctions are increasingly prominent foreign policy tools, but research on the policy process that leads to specific sanction design is limited. Sanctions can have unintended effects on the provision of humanitarian aid in sanctioned countries, which has led to calls for humanitarian exceptions in sanction design. This study focuses on non‐governmental organizations' (NGOs) advocacy for a humanitarian perspective on European Union (EU) sanctions in the period 2020–2021. Building on the Advocacy Coalition Framework and the triangulation of qualitative data sources including interviews and document analysis, this study describes an advocacy coalition of humanitarian NGOs in Brussels, their advocacy strategies and the effectiveness of these strategies. The analysis highlights the coalition's common policy beliefs and documents three advocacy strategies: coalition building, knowledge leadership and lobbying. The analysis then traces the link between these strategies and recent policy changes, namely, clearer European Commission guidelines on the implementation of humanitarian derogations. This policy change was further facilitated by policy brokers and an external shock, the Covid‐19 pandemic. The findings shed light on an understudied design feature of sanctions, i.e., humanitarian exceptions, and on the role of non‐governmental actors in shaping sanction designs.