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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As has been the case since they were first introduced, the UN currently does not impose its own listings under the sanctions but rather sets out a range of measures to be implemented by Member States, including targeted asset freezes.

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.

The EU implemented the UN’s general terrorism sanctions in 2001, by Council Regulation (EC) No 2580/2001. Currently, the EU’s general terrorism sanctions impose asset freezes on autonomously designated people and entities suspected of involvement in terrorism. It implemented what are now 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 and, since 2016, the EU has had the power to make its own autonomous listings under Council Regulation (EU) 2016/1686.

Summary of Current UN Sanctions:

General Terrorism

The UN requires Member States to take several measures designed to combat terrorism, including targeted asset freezes, travel bans, and the criminalisation of providing funds for terrorist acts.

ISIL (Da’esh) & Al-Qaida

Targeted

  • Arms embargo
  • Asset freeze
  • Travel ban

Summary of Current EU Sanctions:

General Terrorism

Targeted

  • Asset freeze

ISIL (Da’esh) & Al-Qaida

Targeted

  • Arms embargo
  • Asset freeze
  • Travel ban

 

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News

OFAC designates Iranian persons involved in intelligence and cyber attacks

Yesterday (13 February), OFAC designated 10 Iranian nationals and 2 Iran-based entities. See OFAC Notice and US Treasury Press Release. New Horizon Organization was designated, pursuant to terrorism-related Executive Order (EO) 13224 (asset freeze), for assisting / sponsoring / supporting the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), namely, by organising international conferences that support the […]

IranIran TerrorismTerrorism

UN & EU de-list 4 people from ISIL & Al-Qaida sanctions

On 8 February 2019, the UN Security Council removed the following 4 people from its ISIL (Da’esh) and Al-Qaida sanctions list: Hassan Abdullah Hersi Al-Turki, Jamal Housni, Malik Muhammad Ishaq, and Lavdrim Muhaxheri. As a result, they will no longer be subject to UN asset freezes, travel bans or arms embargoes. See UN Press Release. […]

TerrorismTerrorism

OFAC sanctions Iran-backed militias & entities linked to Mahan Air

Yesterday (24 January), OFAC designated the following entities pursuant to Executive Order 13224 (counter-terrorism authority): Two Syria-based, Iran-backed militias, the Fatemiyoun Division and Zaynabiyoun Brigade, for providing material support to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). Both entities were also designated pursuant to Executive Order 13553, which targets “serious human rights abuses by the […]

IranIran TerrorismTerrorism

US continues Middle East terrorist sanctions

In January 1995, the US adopted Executive Order 12947, which declared a national emergency with respect to “foreign terrorists who threaten to disrupt the Middle East peace process”, and imposed asset freezes on them. Last week (16 January 2019), President Donald Trump extended those sanctions for 1 year by continuing the national emergency as declared. […]

TerrorismTerrorism

EU Court upholds Hamas’ terrorist sanctions listings

In July 2017, the European Court of Justice allowed the EU Council’s appeal against the General Court’s judgment annulling the terrorist sanctions designation of Hamas (see previous blog). The Court held that the General Court was wrong to have decided that in considering whether a re-listing remained justified on the basis of ongoing terrorist risk, […]

TerrorismTerrorism

Current Sanctions

EU UK

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

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

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

Parent Regulation - Regulation 2580/2001

Council Regulation (EC) No 2580/2001

Amended by:

Council Implementing Regulation (EU) 2019/24

Parent - Common Position 2001/931

Council Common Position 2001/931/CFSP

Amended by:

Council Decision (CFSP) 2019/25

Sanctions and Anti-Money Laundering Act 2018

Sanctions and Anti-Money Laundering Act 2018 (Commencement No 1) Regulations 2018

Sanctions Review Procedure (EU Exit) Regulations 2018