By Maya Lester KC & Michael O’Kane

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By Maya Lester KC & Michael O’Kane

Terrorism

Sanctions regime

Overview

UN Sanctions

The UN enforces two main counter-terrorism sanctions regimes: a general one targeting individuals and entities involved in terrorism, and another specifically focused on ISIL (Da’esh) and Al-Qaida. The general regime was established by UN Security Council Resolution 1373 in September 2001, following the 9/11 attacks. The targeted ISIL (Da’esh) & Al-Qaida regime originated with Resolution 1267 in 1999, initially addressing threats linked to Osama bin Laden and the Taliban. In 2011, Resolutions 1988 and 1989 split the sanctions into separate regimes:

  • one for Afghanistan and the Taliban, and
  • one for ISIL (Da’esh) & Al-Qaida.

These sanctions include asset freezes, travel bans, and arms embargoes on individuals and entities designated by the UN Sanctions Committee.

 

EU Sanctions

EU terrorism sanctions also consist of 2 regimes:

  • general terrorism sanctions (implementing the UN’s terrorism sanctions)
  • ISIL (Da’esh) & Al-Qaida sanctions (which implement the UN’s ISIL sanctions through Council Regulation (EC) No 881/2002 and, since 2016, include provisions for the EU to make its own autonomous listing under Council Regulation (EU) 2016/1686)

The EU implements UN terrorism sanctions via Council Regulation (EC) No 2580/2001 and Council Common Position 2001/931/CFSP.  These measures allow the EU Council to impose asset freezes on individuals and entities involved in terrorism, including those who commit, support, or are associated with terrorist acts or groups.

The EU implements the UN’s ISIL (Da’esh) & Al-Qaida sanctions through Council Regulation (EC) No 881/2002, targeting designated individuals and entities with asset freezes and an arms embargo. Since 2016, the EU has made its own autonomous listings under Council Regulation (EU) 2016/1686.

 

UK Sanctions

The UK’s terrorism sanctions regimes consists of targeted asset freezing/travel ban measures and proscription of terrorist organisations.

The UK’s Terrorist Asset-Freezing etc Act 2010, was repealed by the Sanctions and Anti-Money Laundering Act 2019. It was replaced by a domestic counter-terrorism regime through the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019 and by an international counter-terrorism regime through the Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019. The ISIL (Da’esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019 gives effect to the UK’s UN obligations, imposing asset freezing measures and a travel ban against those designated under the UN ISIL (Da’esh) and Al-Qaida regime.

The UK can proscribe organisations believed to be involved in terrorism under the Terrorism Act 2000. Proscribed organisations are listed in Schedule 2 of TACT 2000 and are published on the UK Government website. It is a criminal offence for a person in the UK to belong to or support a proscribed organisation & a number of related offences.

 

US Sanctions

  • The US counter-terrorism sanctions are imposed by multiple legal authorities: EO 12947 (1995)and EO 13099 (1998) prohibit transactions with terrorists who threaten to disrupt the Middle East peace process.
  • EO 13224which blocks property and prohibited transactions with persons who commit, threaten to commit, or support terrorism. EO 13372 provides a “clarification of certain terrorism” and EO 13886 “modernised sanctions to combat terrorism”.

The Secretary of State can also list countries on its state sponsors of terrorism list. Inclusion on this list results in restrictions on access to US foreign assistance, exports and other restrictions.

Current UN Sanctions

The UN imposes sanctions targeting terrorism under two regimes, one of which targets terrorist actors and organisations generally, and the other targets ISIL (Da’esh) & Al-Qaida. It imposed its general terrorism sanctions on those participating in terrorist acts or supporting terrorists in September 2001 by UN Security Council Resolution 1373 following the 9/11 attacks on the US.

The earliest form of the UN sanctions regime that now specifically targets ISIL (Da’esh) & Al-Qaida was introduced by UN Security Council Resolution 1267 (1999) in relation to Afghanistan, and required all Member States to impose an arms embargo, asset freezes, and travel bans on people and entities associated with Osama bin Laden or the Taliban, as designated by the relevant UN Sanctions Committee.

In 2011, UN sanctions relating to Afghanistan were split into two regimes by UN Security Council Resolutions 1988 and 1989 – one targeting ISIL (Da’esh) & Al-Qaida, and the other specifically relating to Afghanistan and the Taliban. The ISIL (Da’esh) & Al-Qaida sanctions impose asset freezes, travel bans, and an arms embargo on people designated by the relevant UN Sanctions Committee. For more details on the Afghanistan and Taliban sanctions, see the Afghanistan country profile.

Current EU Sanctions

Terrorism Sanctions

The EU implemented the UN’s terrorism sanctions in 2001, by Council Regulation (EC) No 2580/2001 and Council common position 2001/931/CFSP. Under these provisions, the EU Council imposes asset freezes on designated people and entities suspected of involvement in terrorism:

  1. people committing, or attempting to commit, participating in or facilitating the commission of any act of terrorism;
  2. groups or entities committing, or attempting to commit, participating in or facilitating the commission of any act of terrorism;
  3. groups or entities owned or controlled by one or more people, groups or entities referred to in points(i) and (ii); or
  4. people, groups or entities acting on behalf of or at the direction of one or more people, groups or entities referred to in points (i) and (ii).

 

ISIL (Da’esh) & Al-Qaida Sanctions

The EU implemented the UN’s ISIL (Da’esh) & Al-Qaida sanctions in 2002 by Council Regulation (EC) No 881/2002. Those sanctions impose targeted asset freezes and an arms embargo on people and entities designated by the UN Sanctions Committee. Since 2016, the EU has made its own autonomous listings under Council Regulation (EU) 2016/1686.

In February 2024, the EU Council introduced a humanitarian exception to the asset freeze measures initially for 12 months. In February 2025, the Council extended the humanitarian exemption so it lasts indefinitely.

The exception permits “certain categories of humanitarian acts” to engage in transactions with listed people and entities without a licence provided the purpose is to deliver humanitarian assistance or support activities that support basic human needs of people in need. The categories include:

  • organisations and agencies certified as humanitarian partners of the EU or its member states and member states’ specialised agencies

See our Charities & NGOs page for further information.

Current UK Sanctions

Sanctions Regulations

The ISIL (Da’esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019 gives effect to the UK’s UN obligations, imposing asset freezing measures and  travel bans on those designated under the UN ISIL (Da’esh) and Al-Qaida regime.

The Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019 replaces the UK and EU acts which implemented the EU’s autonomous ISIL (Da’esh) and Al-Qaida regime, and its counter-terrorism regime under Common Position 2001/931/CFSP, which imposed asset freezing measures against those determined to have been involved in terrorist acts. It also gives effect to the UK’s obligations under UNSC Resolution 1373 (2001). The Regulations enable the UK to apply sanctions (asset freezes and travel bans) in respect of persons for whom there are reasonable grounds to suspect are or have been involved in terrorist activity, where there is an international nexus.

The Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019  replace Part 1 of the Terrorist Asset Freezing (etc) Act 2001 following its repeal by s59(1) of the Sanctions and Anti-Money Laundering Act 2018. It allows the designation (for asset freezing measures and travel bans) of people, entities and groups where there are reasonable grounds to suspect their involvement in terrorist activity with a UK nexus.

 

Proscribed Terrorist Organisations

Under Section 3 of the Terrorism Act (TACT) 2000, the Home Secretary may proscribe an organisation if the Secretary of State believes it is concerned in terrorism. An organisation is concerned in terrorism if it:

  • commits or participates in acts of terrorism
  • promotes or encourages terrorism
  • prepares for terrorism, or
  • is otherwise concerned in terrorism

Proscribed organisations are listed in Schedule 2 of TACT 2000 and are published on the UK Government website.

It is a criminal offence for a person in the UK to:

  • belong to a proscribed organisation;
  • invite support for a proscribed organisation;
  • recklessly express support for a proscribed organisation;
  • arrange a meeting in support of a proscribed organisation;
  • wear clothing or carry articles in public which arouse reasonable suspicion that an individual is a member or supporter of a proscribed organisation; or
  • publish an image of an article such as a flag or logo in the same circumstances.

The penalties for proscription offences can be a maximum of 14 years in prison and/or an unlimited fine. The investigation and prosecution of offences relating to proscribed organisations is a matter for the police and the Crown Prosecution Service.

Organisations can apply to the Home Secretary to be de-proscribed under s4 of TACT 2000. The Government has 90 days to respond. If the application is rejected, the organisation may appeal to the Proscribed Organisations Appeal Commission under s5 of the Terrorism Act, the outcome of which may be appealed to the courts on questions of law under s6.

 

Review of Terrorism Legislation

The Independent Reviewer of Terrorism Legislation reviews the operation of the UK’s laws on terrorism, and publishes findings and recommendations in regular reports. These reports are then laid before Parliament, to inform the public and political debate.

Jonathan Hall KC, Independent Reviewer since 2019, has published 5 annual reports:

Previous reports are available in the drop-down below.

Current US Sanctions

Sanctions Regimes

The US counter-terrorism sanctions are imposed by multiple legal authorities.

EO 12947 (1995) and EO 13099 (1998) prohibit transactions with terrorists who threaten to disrupt the Middle East peace process.  After 9/11, EO 13224  blocked property and prohibited transactions with persons who commit, threaten to commit, or support terrorism.  EO 13372 provides a “clarification of certain terrorism” and EO 13886 “modernised sanctions to combat terrorism”.

Key Regulations are:

 

State Sponsors of Terrorism

Countries determined by the Secretary of State to have repeatedly provided support for acts of international terrorism are designated as State Sponsors of Terrorism pursuant to three laws:

  • section 1754(c) of the National Defense Authorization Act for Fiscal Year 2019,
  • section 40 of the Arms Export Control Act, and
  • section 620A of the Foreign Assistance Act of 1961).

4 countries are currently listed on the US’ state sponsors of terrorism list: Cuba, DPRK, Iran, and Syria.  Sanctions resulting from designation under these authorities include restrictions on U.S. foreign assistance; a ban on defence exports and sales; certain controls over exports of dual use items; and miscellaneous financial and other restrictions.

 

Foreign Terrorist Organisations or Specially Designated Global Terrorists

Organisations (including cartels, following an EO on 20 January 2025) can be designated as:

Being designated as a Foreign Terrorist Organisation means:

  • a US person cannot provide the listed cartels with “material support or resources” (defined in 18 U.S.C. § 2339A(b)(1))
  • representatives and members of the listed cartels (if not US citizens) can be removed from the US
  • any US financial institution that becomes aware that it has/controls funds in which the listed cartels have an interest must freeze the funds and report them to OFAC

Being designated as a global terrorist group on the SDN list under EO 13224 means that unless authorised by OFAC:

  • all property and interests in property of the listed cartels in the US are blocked;
  • any transaction/dealing by a US person with the listed cartels’ property or interests in property is blocked; and
  • any transaction by a US person or within the US that evades or seeks to evade the prohibitions is also prohibited.

Other Countries Sanctions

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