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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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 […]

LibyaLibya NicaraguaNicaragua TerrorismTerrorism GuineaGuinea MoldovaMoldova BurundiBurundi

EU adds French national to the ISIL Da’esh & Al-Qaeda sanctions list

The EU has added French national Guillaume Pirotte to its autonomous ISIL Da’esh and Al-Qaeda sanctions list (asset freeze). See Council Implementing Regulation (EU) 2019/1943 and Council Decision (CFSP) 2019/1944.


OFAC designates ISIS financial procurement agents, companies & an NGO

OFAC has designated 2 Turkey-based ISIS procurement agents and 4 ISIS-linked companies operating in Syria, Turkey, and across the Gulf and Europe, for providing financial and logistical support to ISIS. The 2 procurement agents, Ismail and Ahmet Bayaltun are alleged to have provided support to ISIS fighters by supplying equipment through their company ACL Ithalat […]


UNSC & EU – Iraq & ISIS (Da’esh) and Al-Qaida sanctions de-listings

The United Nations Security Council (UNSC) has removed 2 entities from its Iraq sanctions list: State Organisation for Irrigation Projects and State Organisation for Land Reclamation. They are therefore no longer subject to asset freezing measures. UN Press Release. The EU has aligned with this decision, see Commission Implementing Regulation (EU) 2019/1853. ISIS (Da’esh) and […]

TerrorismTerrorism IraqIraq

EU General Court annuls Hamas 2018 designation for procedural flaws

The General Court has annulled the March 2018 listing of Hamas  in Case T-308/18 (4 September 2019) because the statement of reasons for including Hamas was defective – it was unsigned, had no heading, and could not be identified as an act of the EU Council. The President of the Council and Secretary General are […]


Current Sanctions


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

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

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

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:

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)