Consultant – Sanctions, Operational Impediments, and International Law

April 27, 2020
Washington, D.C.
Post Type
Experience (minimum)
2-5 Years
Education (minimum)
Travel Required?
Not specified
Base Salary
Not specified



As COVID-19 spreads globally, States adopt measures to limit transmission and mount their responses to the crisis, existing sanctions regimes and new bureaucratic impediments complicate the COVID-19 response and ongoing humanitarian operations. These affect the timely movement of people and goods, access to vulnerable people, and authorization for humanitarian actors to carry out operations, among other constraints.

Many humanitarian NGOs and NGO consortia do not have in-house capacity to quickly determine how domestic or international law applies to these restrictions or what options could be pursued to address them in their operations.

Some trends in the type and effects of these impediments are emerging across country contexts and regions and it will be increasingly important to ensure that humanitarian actors address them in a timely and systematic, rather than ad hoc, manner while drawing on existing good practice as relevant.

Purpose and Scope

The purpose of this consultancy is to make timely and appropriate advice available to operational humanitarian NGOs and NGO consortia responding to humanitarian need in the context of COVID-19.

The focus of the consultancy will be on the priority issues and questions posed by operational NGOs, NGO consortia and NGO HQs while also anticipating potential challenges based on global trends and emerging legal, policy, and contractual measures which may be taken by States or multi-lateral entities.

Issues are expected to relate to newly imposed restrictions in response to COVID-19, donor contractual restrictions, existing sanctions regimes, counter-terrorism measures, import/export law, international humanitarian and human rights law, refugee law, public international law, and applicable domestic law.

Key Requirements and Expected Outputs

The consultant will:

  1. Work with InterAction staff to review and prioritize questions and issues from operational NGOs, NGO consortia and NGO HQs, assess their policy, practice, and legal implications, and provide recommendations, for example, regarding additional information needed to address the issue, arguments to use (or avoid) with relevant authorities and policymakers, putting in place good practice protocols/arrangements, etc. While not constituting official legal advice, these recommendations will be disseminated by InterAction to the relevant NGOs as well as used to inform InterAction’s own work to influence broader inter-agency or government policy.

Initial priorities include:

  • international travel restrictions impeding travel of humanitarian personnel, restrictions on international shipment of relief supplies, and opportunities to ensure fast track entry and clearance of relief items;
  • donor government policy and contractual restrictions and existing sanctions regimes on the COVID-19 humanitarian response, including for example in Iraq, Nigeria, Venezuela, and Syria;
  • negotiations with government authorities regarding in-country humanitarian access to vulnerable populations and area-based telecommunications restrictions.
  1. Monitor, and work with InterAction staff to catalogue, ongoing country-specific and international developments and emerging issues with a view to anticipating trends and maintaining up-to-date guidance for operational NGOs, NGO consortia, and to aid InterAction in developing opportunities to address them.
  2. Be available for bi-lateral teleconferences or group calls to discuss the issues of concern with operational NGOs and NGO consortia. These consultations may be with individuals based in the field or in organizational regional hubs or HQs.
  3. Be available to accompany InterAction staff in discussions with UN counterparts and donor governments, whether bi-laterally or in an inter-agency setting, where the impact of sanctions and other operational impediments are being addressed.
  4. Be available for advice on other matters related to applicable international law emerging in relation to the global COVID-19 crisis.
  5. Prior to the end of the consultancy, provide InterAction with a write-up of key issues and lessons learned along with written advice and concrete recommendations on observed and emerging trends, InterAction’s role, and potential strategies to address them to help ensure an operational environment conducive to timely humanitarian response in the context of the global COVID-19 crisis.

In addition, as needed and as this work evolves, the consultant may be requested to:

  • Provide expert advice to support InterAction staff at key moments to influence UN Security Council resolutions, U.S. or other government policies which may affect entitlements to assistance and/or have other normative or operational implications for humanitarian action.
  • Work with InterAction staff to document emerging good practice regarding the issues addressed in this consultancy with a view to contributing this good practice to future humanitarian action.

Hours and Remuneration

  • This consultancy is planned for an initial time frame of 4 weeks and may be extended by mutual agreement of InterAction and the consultant.
  • It is anticipated that the consultant will work a maximum of 3 days per week for a period of an initial period of 4 weeks.

Remuneration for this consultancy will follow USAID guidance on daily rates. 

Management and Coordination

  • This consultancy will be managed and overseen by Lindsay Hamsik, Senior Manager for Policy, on InterAction’s Humanitarian Policy and Practice Team. An internal team will be stood up to inform the consultancy and provide relevant data regarding NGO operations and emerging impediments.

Application Requirements

Applicants should submit a maximum one-page proposal on how they intend to approach the consultancy, prospective deliverables and an outline of projected costs, including hourly rates.

Interested candidates should send their resume and proposal to indicating Consultant – Sanctions, Operational Impediments, and International Law in the subject line

The position will remain open until filled but applications received before 5 May 2020 are preferred. Due to the expected volume of applications, only finalists will be contacted



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