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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TAFA Quarterly Report: October – December 2019

HM Treasury has published its quarterly report on the operation of the UK’s counter-terrorist asset freezing regime from 1 October to 31 December 2019. See Notice. The report shows that, as of 31 December, £9,000 continued to be frozen under the Terrorist Asset-Freezing etc. Act 2010 (TAFA 2010) powers. £18k across 3 accounts remained frozen under the EU’s counter-terrorism sanctions, and …


Germany designates Hezbollah as a terrorist organisation & confiscates assets

The German Federal Minister of the Interior, Horst Seehofer, has proscribed Hezbollah in its entirety (not just the military wing) as a terrorist organisation under the Act Governing Private Associations. The basis for designation is that the activities of Hezbollah violate criminal law, and the organisation opposes concepts of international understanding by openly calling for the “violent elimination” of the …


UK implements UN terrorism de-listings

The UK Office of Financial Sanctions Implementation has removed 4 people from the UK ISIL (Da’esh) & Al-Qaida sanctions regime: Amran Mansor, Abderrahmane Kifane, Son Hadi bin Muhadjir, and Abdul Rahim Al-Talhi. Notice. The UN (and therefore the EU) delisted the first 3 in 2014, and Mr Al-Talhi in 2015. EU measures: Commission Implementing Regulation (EU) 369/2014 and Commission Implementing …


US first terrorism designation of white supremacist group

The US State Dept has designated the Russian Imperialist Movement (RIM), described as a far-right nationalist group, and 3 of its leaders, Stanislav Anatolyevich Vorobyev, Denis Valliullovich Gariev, and Nikolay Nikolayevich Trushchalov as Specially Designated Global Terrorists (SDGTs) under Executive Order 13224 (asset freeze and travel ban). This is the first time the US has added a white supremacist group …


UNSC & EU delists 1 person from ISIL & Al-Qaida sanctions

The UN Security Council has removed Ibrahim Mohamed Khalil from its ISIL and Al-Qaida sanctions list, and he will therefore no longer be subject to asset freezing measures, a travel ban or arms embargo. The delisting decision was made following a request submitted through the Office of the Ombudsperson. See UN press release. The EU aligned with this decision on …


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

Council Implementing Regulation (EU) 2020/19

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

Council Decision (CFSP) 2020/20

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

Commission Implementing Regulation (EU) 2020/259

Commission Implementing Regulation (EU) 2020/288

Commission Implementing Regulation (EU) 2020/390

Commission Implementing Regulation (EU) 2020/483

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

Commission Implementing Regulation (EU) 2020/218

Parent - Common Position 2001/931

Council Common Position 2001/931/CFSP

Amended by:

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)