On 5 August 2019 the Trump Administration issued an executive order imposing additional sanctions on the Government of Venezuela that specifically allows “transactions related to provision of articles such as food, clothing and medicine intended to be used to relive human suffering.” The next day the Department of Treasury issued a guidance document that
In Safeguarding Humanitarian Access in Sanctions Regimes Alice Debarre of the International Peace Institute argues that although sanctions regimes are used with the assumption that they minimize harm, they actually can devastate civilian populations, particularly those that rely on humanitarian aid, including refugees and internally displaced persons. Sanctions regimes also affect humanitarian organizations’ ability to deliver aid on the basis of need alone and not be directed by the political objectives of sanctions programs.
The U.S. government maintains two lists containing entities (State's Foreign Terrorist Organizations (FTO) & Treasury's Specially Designated Nationals (SDN)) it believes engage in terrorist activity. It is illegal to provide these groups with material support which is defined broadly in the law to include tangible goods like food or clothing, medical services, and training in conflict mediation.
But the laws designed to starve the terrorists also make it nearly impossible for humanitarian actors to reach or offer assistance to civilians living in territory controlled by a blacklisted group. That means that in conflict zones or natural disaster areas where these groups are active, providing medical services or distributing non-medicinal necessities such as clean water, tents, blankets, food can be prohibited.
A group of 13 international non-governmental organizations (INGOs) that provide humanitarian aid in areas of greatest need call on the UN’s Office for Coordination of Humanitarian Affairs (OCHA) to provide the “fullest support for efforts to protect principled humanitarian action from the impact of counterterrorism measures.” Noting that this year is the 70th anniversary of the Geneva Conventions, the June 19 letter states that although the UN has sa