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Counter terrorist financing legislation has dramatically impacted the ability of humanitarian actors to access financial service and shaped the ability of humanitarian organisations to reach some of the most vulnerable populations in Syria and Yemen. U.S. counterterrorism laws have forced banks into quasi-regulatory roles in the fight against terrorist financing. Profound uncertainty about how these new laws should be interpreted, soaring regulatory fines imposed on banks for breaching the rules combined with statements and directives from national and international regulatory bodies such as the Financial Action Task Force (FATF) identifying that the not-for-profit sector is particularly vulnerable to abuse by terrorists, has established within the financial sector a global pattern of risk aversion. Consequently, banks have become increasingly cautious in their handling of humanitarian agency financial affairs; closing accounts and halting urgent financial transfers. This has seriously undermined the ability of humanitarian organisations to reach civilian ‘populations in need’ under the control of proscribed terrorist groups such as Islamic State. The risk aversion of banks has inadvertently found itself reproduced within the governance and regulatory structures of humanitarian institutions and, crucially, distorted patterns of emergency assistance coverage in many crises. NGOs have increasingly adopted a ‘precautionary approach’ to managing the risk of bank’s closing their accounts and limited their ability to reach some of the most vulnerable populations whilst curtailing innovation. It has also impacted on the governance and structure of the humanitarian system, enabling the exercise of new techniques of power over significant parts of the humanitarian system. This panel explores the profound and damaging impact of this new régime in Syria and Yemen