Sanctions Profile: Terrorism

At a glance

The UN imposes sanctions targeting terrorism under two regimes, one of which targets terrorist actors and organisations generally, and the other specifically targets ISIL (Da’esh) & Al-Qaida. It imposed its general terrorism sanctions, on all 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.

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UK adds Hizballah (not just military wing) to UK’s terrorist asset freeze list

OFSI has designated Hizballah as one entity under the Terrorist Asset-Freezing etc Act 2010 (TAFA). As a result, it is subject to an asset freeze with immediate effect. Notice. Hizballah Military Wing is no longer designated as a separate entity under TAFA in the UK but is still subject to EU asset freezing measures under Council Regulation (EC) 2580/2001.


EU renews its terrorism sanctions list

In December 2001, the EU adopted Council Common Position 2001/931/CFSP, which imposed asset freezing measures against a number of people, groups and entities determined to be “involved in terrorist acts”. The EU has renewed that terrorism sanctions list by adopting Council Implementing Regulation (EU) 2020/19 and Council Decision (CFSP) 2020/20, (15 individuals and 21 groups/entities are currently listed). Accordingly, Council …


US lists 3 people and 17 companies for supporting Hizbollah

OFAC has designated 2 Lebanese and 1 DRC-based businessmen, and their affiliated companies (17 in total), pursuant to Executive Order 13224, as amended, which imposes sanctions on terrorists, and those providing support to terrorism. Lebanese national Nazem Said Ahmad, said to be one of Hizbollah’s main donors, reportedly generated funds through his businesses operating within the “blood diamond” trade. DRC-based …


OFSI renews TAFA designation

The UK’s Office of Financial Sanction Implementation (OFSI) has renewed the listing of Khalid Shaikh Mohammed under the Terrorist Asset-Freezing etc. Act 2010. As a result, the asset-freezing prohibitions contained in the Act continue to apply to Mr Mohammed. OFSI Notice.


Third countries align with 7 EU sanctions regimes

In October, the EU adopted: Council Decision (CFSP) 2019/1663, which renewed sanctions against 3 Libyan nationals for 6 months; Council Decision CFSP 2019/1720, which established a new sanctions regime against Nicaragua in view of the recent human rights abuses in the region (see post); Council Decision (CFSP) 2019/1721, and Council Decision (CFSP) 2019/1722, which renewed for 1 year restrictive measures …

LibyaLibya NicaraguaNicaragua TerrorismTerrorism GuineaGuinea MoldovaMoldova BurundiBurundi

Current Sanctions


Consolidated - ISIL (Da'esh) & Al-Qaida

Council Regulation (EU) 2016/1686

Parent Regulation - ISIL (Da’esh) & Al-Qaida

Council Regulation (EU) 2016/1686

Amended by:

Council Implementing Regulation (EU) 2018/281

Council Implementing Regulation (EU) 2018/999

Council Implementing Regulation (EU) 2018/1539

Council Implementing Regulation (EU) 2019/270

Council Implementing Regulation (EU) 2019/1717

Council Implementing Regulation (EU) 2019/1943

Consolidated - ISIL (Da'esh) & Al-Qaida

Council Decision (CFSP) 2016/1693

Parent Decision - ISIL (Da’esh) & Al-Qaida

Council Decision (CFSP) 2016/1693

Amended by:

Council Decision (CFSP) 2017/1560

Council Decision (CFSP) 2018/283

Council Decision (CFSP) 2018/1000

Council Decision (CFSP) 2018/1540

Council Decision (CFSP) 2019/271

Council Decision (CFSP) 2019/25

Council Decision (CFSP) 2019/1721

Council Decision (CFSP) 2019/1944

Council Decision (CFSP) 2019/1721

Consolidated - ISIL (Da'esh) & Al-Qaida

Council Regulation (EC) 881/2002

Parent Regulation - ISIL (Da’esh) & Al-Qaida

Council Regulation (EC) No 881/2002

Amended by:

Commission Implementing Regulation (EU) 2018/733

Commission Implementing Regulation (EU) 2018/816

Commission Implementing Regulation (EU) 2018/855

Commission Implementing Regulation (EU) 2018/888

Commission Implementing Regulation (EU) 2018/1033

Commission Implementing Regulation (EU) 2018/1204

Commission Implementing Regulation (EU) 2018/1494

Commission Implementing Regulation (EU) 2018/1562

Commission Implementing Regulation (EU) 2018/1809

Commission Implementing Regulation (EU) 2019/257

Commission Implementing Regulation (EU) 2019/353

Consolidated - Regulation 2850/2001

Council Regulation (EC) 2850/2001

Parent Regulation - Regulation 2580/2001

Council Regulation (EC) No 2580/2001

Amended by:

Council Implementing Regulation (EU) 2019/24

Commission Implementing Regulation (EU) 2019/507

Commission Implementing Regulation (EU) 2019/622

Commission Implementing Regulation (EU) 2019/791

Commission Implementing Regulation (EU) 2019/850

Commission Implementing Regulation (EU) 2019/1353

Commission Implementing Regulation (EU) 2019/1731

Parent - Common Position 2001/931

Council Common Position 2001/931/CFSP

Amended by:

Council Implementing Regulation (EU) 2020/19

Council Decision (CFSP) 2020/20

Terrorist Asset-Freezing etc. Act 2010

Terrorist Asset-Freezing etc. Act 2010 (Overseas Territories) (Amendment) Order 2017/157

Terrorist Asset-Freezing etc. Act 2010 (Guernsey) Order 2011/1082

Terrorist Asset-Freezing etc. Act 2010 (Commencement) Order 2011/2835

Terrorist Asset-Freezing etc. Act 2010 (Overseas Territories) Order 2011/750

Terrorist Asset-Freezing etc. Act 2010 (Isle of Man) Order 2011/749

Act of Sederunt (Rules of the Court of Session Amendment No. 6) (Terrorist Asset-Freezing etc. Act 2010) 2010/459 (Scottish SI)

Terrorist Asset-Freezing etc. Act 2010 (Isle of Man) (Revocation) Order SI 2015/1763

ISIL and Al Qaida (Asset Freezing) (Amendment) Regulations 2016 (SI 2016/937)

The Export Control (Al-Qaida and Taliban Sanctions) Regulations 2011 (SI 2011/2649)