An urgent situation

Last year marked the continuation of a grim global trend: Armed conflicts are becoming both more common and more devastating to human rights. In 2024, the world experienced its most war-torn year since World War II - with 2023 a close second - owing to a sharp global rise in both interstate conflicts and militant group activity. From Ukraine and Gaza to Myanmar and Sudan, human rights and security are under concerted attack in an escalation of violence that global leaders describe as the most urgent threat currently confronting the world.

As they become more common, conflicts have also become more entrenched, more threatening to civilians, and more dangerous to journalists, human rights defenders, and civil society as a whole. UN officials have warned that governments around the world seem increasingly unable and/or unwilling to safeguard the fragile rules of war and international law in conflict situations. States’ increasing willingness to disregard the distinction between civilians and combatants places the very fabric of the rules-based international order in jeopardy.

This increasingly violent landscape is a breeding ground for human rights abuses, as civilians become targets of atrocities and groups already at risk of discrimination and human rights violations - including women, LGBTQ+ people and people with disabilities - are rendered even more vulnerable. At the same time, the attacks on civil society and international institutions have made our fundamental human rights even more difficult to protect.

Against this dire situation, communities and civil society groups across the world are continuing the fight to claim, affirm, and safeguard their human rights. In this context, businesses and financial institutions play a crucial role. Businesses have an internationally recognised responsibility to respect human rights and can even contribute significantly to the promotion of human rights, especially as states increasingly neglect their own human rights responsibilities. 

In practice, however, businesses contribute to the violations of human rights in conflict zones with an alarming frequency. The UN’s Office of the High Commissioner for Human Rights (OHCHR) notes that the “worst forms of business-related human rights abuse tend to happen in conflict-affected contexts”, as businesses acting in conflict zones are likely to operate without a clear human rights regime and at a heightened risk of contributing to conflict-related human rights abuses. Given these heightened risks, the efforts of state, international, and civil society actors are crucial in ensuring that banks act decisively to meet their human rights responsibilities in conflict zones.

Role of banks

Recent conflicts across the world have seen commercial banks play significant roles both in affirming and respecting human rights and in perpetuating human rights violations. Banks can be crucial players in assisting with the facilitation of aid delivery, in financing post-conflict reconstruction efforts, and in using their leverage over business relationships to pressure them to respect human rights in their own operations. In several cases, as in the context of Russia’s war of aggression against Ukraine, some banks have also pursued a policy of responsible disengagement from a conflict zone to avoid contributing to a host state’s rampant human rights violations.

Conversely, the crucial role that commercial banks play in financing the operations of business relationships and providing the financial architecture of the states in which they operate means that banks may also facilitate human rights violations. As set out in the UN Guiding Principles on Business and Human Rights (UNGPs), which set authoritative standards for businesses’ human rights responsibilities, the “risk of gross human rights abuses is heightened in conflict-affected areas”, as banks face a heightened risk of exacerbating conflicts and involving themselves in human rights violations through their own operations as well as the operations of their clients. 

The UNGPs describes the variety of ways in which business enterprises can be involved in human rights violations. In 2017, the OHCHR set out further guidance clarifying how commercial banks specifically might be involved in such violations:

• Banks can cause human rights violations themselves if the human rights violation directly results from their own operations; e.g., when Russian commercial banks in occupied Ukraine allegedly forced Ukrainians to take Russian citizenship to access crucial financial services.

• Banks can also contribute to human rights violations if they facilitate or incentivise a business relationship (e.g. a client) to cause human rights harms, or if they consistently fail to use their leverage to prevent clients from causing such harms. The UN’s Special Rapporteur on the situation of human rights in the Palestinian territories occupied since 1967, for example, has outlined how major commercial banks have enabled the government of Israel to continue its commission of gross human rights violations in Gaza by underwriting bonds issued to finance Israel’s war effort.

• Finally, banks can be directly linked to human rights violations if their business relationships cause human rights harms, even if the bank is not directly facilitating these harms. BankTrack’s partners, for example, have documented financial ties between a series of Southeast Asian banks and companies responsible for human rights violations in Myanmar, directly linking these banks to human rights harms even if they are not specifically providing loans for business activities which violate human rights.

Accordingly, it is especially crucial for banks to ensure that they avoid involvement in human rights harms in conflict-affected areas.

What banks must do

Like all businesses, banks are subject to clearly delineated international responsibilities to respect human rights, which are authoritatively outlined in the UNGPs and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (OECD Guidelines), among others.

These documents clarify that banks have a responsibility to avoid causing or contributing to human rights harms and to address these harms when they occur, including by providing remedy to affected groups. Banks also have a responsibility to mitigate human rights harms to which they are directly linked, including by using their leverage over clients to pressure them to address and end these human rights harms, and by considering terminating a relationship where they cannot effectively exert leverage. 

BankTrack’s Banks and Human rights campaign seeks to ensure that banks comply with their internationally recognised human rights responsibilities. To do this, banks must:

1. Publicly commit to respect human rights;

2. Implement human rights due diligence to assess actual and potential impacts, act upon the findings and track responses;

3. Avoid financing companies that cause human rights violations that are systematic or that they refuse to address;

4. Report on how they have managed and remedied specific adverse impacts, with a focus on the most severe impacts identified by the bank;

5. Develop effective channels to address grievances from anyone impacted by their activities;

6. Commit to transparency, for example so that affected communities can access information on who is financing projects that affect them.

As the UNGPs and the OECD Guidelines make clear, these human rights responsibilities are heightened further in conflict-affected situations. Because the risks of human rights violations are heightened in conflict-affected areas, banks which conduct business activities in conflict zones have additional responsibilities, including heightened operational standards and possible disengagement. They also face a series of additional legal obligations in conflict-affected areas, as banks have an obligation to respect international law even when the states in which they operate fail to do so.

To meet their additional human rights responsibilities and obligations in conflict zones, banks must:

1. Implement and conduct heightened human rights due diligence (hHRDD) in line with the recommendations of the UN Development Programme;

2. Implement and conduct heightened legal due diligence in connection with the standards set by international humanitarian law;

3. Adopt specific human rights-related financial policies in connection with clients’ business activities in conflict areas to exclude financing for businesses which contribute to violations of international law;

4. Use their leverage on clients operating in conflict zones to ensure that these clients do not cause or contribute to human rights harms, and promptly divest from clients which fail to address adverse human rights impacts in conflict zones;

5. Consider responsibly disengaging from conflict-affected areas where they cannot guarantee that their business operations will not cause or contribute to human rights harms;

6. Publicly commit to respecting and complying with international law across the entirety of their operations.

What BankTrack does

BankTrack’s banks and conflict project works to advance the three long-term goals set by the Banks and Human Rights campaign:

• Banks act to prevent and address specific human rights abuses linked to their finance;

• Banks fully implement the UN Guiding Principles on Business and Human Rights;

• Banks avoid contributing to human rights violations arising from global conflict.

Currently, BankTrack’s banks and conflict project is focused specifically on the following medium-term goals:

• Banks commit to suspending all corporate and investment banking activities in Russia in wake of the illegal invasion of Ukraine;

• Banks avoid causing or contributing to human rights and international law violations arising from Israel’s illegal activities in the Occupied Palestinian Territories;

• Banks strengthen their financing policies to avoid contributing to clients’ adverse human rights impacts in conflict zones.

To achieve these goals, we use the following tactics:

• Mapping finance flows: We conduct research on bank finance for companies violating human rights in conflict zones and publish investigative reports into bank activities in conflict zones which may violate domestic and international legal frameworks.

• Strengthen bank policies: BankTrack's Human Rights Benchmark project assesses large international banks on the extent to which they are fully implementing the UN Guiding Principles. The project assesses banks on a wide variety of policies which carry crucial weight for their activities in conflict zones. We also engage directly with banks to ensure that banks strengthen their conflict-related human rights policies.

• Target Dodgy Deals: We target banks involved in financing specific projects and companies violating human rights and legitimate interests of communities, seeking banks to either cut or refrain from financing or exert their influence on clients to end human rights violations. This includes continued bank involvement in conflicts, including the Russian invasion of Ukraine and the Israeli-Palestinian conflict.

• Engage with banks: We engage with banks on a series of issues related to their activities in conflict zones, including by directly calling on banks to exit Russia through open letters and appearances at bank’s Annual General Meetings and by engaging with banks on the findings of publications such as the Don’t Buy Into Occupation report.

• Engage with bank stakeholders: We engage with a range of bank stakeholders, including affected communities, shareholder groups, banking sponsorship benefactors, and transnational standard-setters including the UN Office of the High Commissioner for Human Rights and the OECD. We also engage with national and international regulators and legislators on strengthening guidelines and legal frameworks governing bank conduct in conflict zones.

• File complaints: Where appropriate we may file complaints on bank-financed activities with relevant recourse mechanisms, such as those of development banks and the National Contact Points of the OECD as well as those of national and international regulators. We also assist legislators in filing parliamentary inquiries related to the regulation of bank activities in conflict zones, where appropriate.

• Strengthen movements: We provide training to fellow campaigners on the human rights responsibilities of banks and the state of their human rights policies. We also assist stakeholders directly affected by bank conduct in conflict zones in their engagement with banks and support the finance-related activities of coalitions including B4Ukraine and Don’t Buy Into Occupation.

As part of our project on Banks and Russian Aggression in Ukraine, BankTrack is keeping track of how banks globally respond to the Russian invasion in Ukraine, based on an analysis of their public policies on engagement with the Russian market as well as on financial data derived from Western banks' Russian subsidiaries' filings with the Central Bank of Russia. The Banks and Russia tracker was last updated in August 2025 and can be accessed here. An overview is also available below.

As part of our work with the Don't Buy Into Occupation coalition, we assist in publishing an annual report on the financial relationships between European financial institutions (including commercial banks) and companies that help sustain Israel's violations of international law in the Occupied Palestinian Territory. The fifth Don't Buy Into Occupation report, published in November 2025, is available here.