By Maya Lester KC & Michael O’Kane

Sanctions Profile: Egypt

At a glance

EU sanctions (asset freeze) relating to Egypt were first imposed in 2011, by Council Decision 2011/172/CFSP and Council Regulation (EU) No 270/2011, in the aftermath of the Arab Spring.

On 15 March 2021, the EU adopted Council Regulation (EU) 2021/445 and Council Decision (CFSP) 2021/449, which revoked the framework imposing sanctions on individuals identified as responsible for the misappropriation of Egyptian state funds.

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ECJ annuls Mubarak et al EU Egypt sanctions designations

The EU General Court has confirmed the unlawfulness of the EU sanctions, on Hosni Mubarak (deceased) and his relatives, Gamal Mubarak, Alaa Mubarak, Heidy Rasekh, Khadiga El Gammal and Suzanne Saleh Thabet (Cases  T335/18, T338/18 and T327/19). A previous judgment of the European Court of Justice annulled the family’s 2016 and 2017 listings, and Hosni Mubarak’s 2018 listing (previous post). …


EU revokes Egypt misappropriation sanctions regime & delists 9

The EU Council has revoked its framework that established a sanctions regime against people identified as responsible for the misappropriation of state funds in Egypt. As a result, sanctions currently targeting 9 Egyptian nationals will be lifted. The framework was first introduced in 2011 in the aftermath of the Arab Spring. The press release says that the EU’s sanctions are …


ECJ annuls Mubarak et al Egypt misappropriation sanctions listings

The European Court of Justice (the EU appeals court) has overturned the lower court judgments and has annulled the inclusion of Hosni Mubarak, the former President of Egypt, his wife Suzanne Thabet, their sons Gamal and Alaa Mubarak, and their sons’ wives Khadiga El Gammal and Heddy Rassekh, on the EU’s Egypt sanctions.  All previous EU judgments on the Egypt …


Third countries align with EU Bosnia & Herzegovina and Egypt sanctions

On 23 March 2020, the EU Council adopted Decision (CFSP) 2020/435, which renewed its sanctions regime on Bosnia & Herzegovina for 1 year (see post). North Macedonia, Montenegro, Albania, Iceland, Liechtenstein and Georgia have aligned themselves with this decision. The countries listed above, as well as Serbia, Bosnia & Herzegovina, Norway, Ukraine and Moldova have also aligned themselves with the …

EgyptEgypt Bosnia & HerzegovinaBosnia & Herzegovina

EU renews Egypt sanctions for 1 year

The EU has renewed sanctions on Egypt for 1 year until 22 March 2021. Council Implementing Regulation (EU) 2020/416 and Council Decision (CFSP) 2020/418. The Council has amended President’s Mubarak’s entry to say that he has died, but his “activities are subject to judicial proceedings or an asset recovery process by the Egyptian authorities following a final court ruling in …


Current Sanctions



Council Regulation (EU) No 270/2011

Parent Regulation

Council Regulation (EU) No 270/2011

Amended by:

Council Regulation (EU) No 1099/2012

Council Regulation (EU) No 517/2013

Council Implementing Regulation (EU) 2017/490

Council Implementing Regulation (EU) 2017/491

Council Implementing Regulation (EU) 2018/465

Council Implementing Regulation (EU) 2019/459

Council Implementing Regulation (EU) 2020/416

Council Regulation (EU) 2021/445


Council Decision 2011/172/CFSP

Parent Decision

Council Decision 2011/172/CFSP

Amended by:

Council Decision 2012/159/CFSP

Council Decision 2012/723/CFSP

Council Decision 2013/144/CFSP

Council Decision 2014/153/CFSP

Council Decision (CFSP) 2015/486

Council Decision (CFSP) 2016/411

Council Decision (CFSP) 2017/496

Council Implementing Decision (CFSP) 2017/498

Council Decision (CFSP) 2018/466

Council Decision (CFSP) 2019/468

Council Decision (CFSP) 2020/418

Council Decision (CFSP) 2021/449

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