; the European Union likewise sanctioned Foz for funding the Military Security Shield Forces, a pro-government militia responsible for severe human rights abuses. (10) United Nation agencies and international NGOs are required to purchase mobile phones from Syriatel, a company owned by Rami Makhlouf, a cousin of Bashar al-Assad who is sanctioned for corruption and whose involvement in human rights abuses in Syria is well documented. (11) The Assad regime has regularly siphoned humanitarian funds for the war effort and bypassed international sanctions through exploiting humanitarian exemptions. (12) On July 15, 2019, United Nations High Commissioner for Refugees (UNHCR) Middle East Director Amin Awad recognized in an interview with The National that the United Nations has no procedure for assessing ownership and partnerships of suppliers it uses for procurement in Syria: I do not have a mechanism where we comb every single contract to see do you have one, 10 or 90 percent connection with the regime or not. . (13) On June 28, 2019, Human Rights Watch published a comprehensive report with the following conclusion: While seemingly benign, the Syrian government’s aid and reconstruction policies are being used to punish perceived opponents and reward its supporters. … The Syrian government’s aid framework undermines human rights, and donors need to ensure they are not complicit … . . 3. Statement of policy It is the policy of the United States that— (1) the delivery of assistance funded by the United States through the United Nations must meet reasonable expectations that aid reaches its intended recipients; (2) programming provided through the United Nations based on United States funding should be determined according to greatest need, not only greatest access