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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TGTE wins appeal in the UK Proscribed Organisations Appeal Commission against proscription of LTTE as terrorist organisation

The Proscribed Organisations Appeal Commission (POAC) has given judgment in Arumugam and Others v Secretary of State for the Home Department, (judgment here), allowing an appeal brought by members of the Transnational Government of Tamil Eelam (for whom Maya Lester QC appeared) against the decision of the UK Home Secretary to refuse their application to remove the Liberation Tigers of Tamil Eelam …


US adds Al-Qaida financier to SDN list

OFAC has added Australian national Ahmed Luqman Talib to the list of specially designated nationals pursuant to Executive Order 13224 (counter-terrorism sanctions), as amended, for having materially assisted, sponsored, or provided financial or material support to, Al-Qaida . OFAC Notice, press release and State Department press release. Additionally, the Australian based gemstone company Talib and Sons PYT LTD, owned, controlled …


EU ISIL/Da’esh and Al-Qaida sanctions renewed for another year

The EU’s sanctions regime concerning ISIL/Da’esh, Al-Qaida, and people and entities associated or supporting them, has been extended until 31 October 2021. Press release. Following Council Decision (CFSP) 2016/1693 in 2016, the EU has been able to adopt targeted restrictive measures against ISIL/Da’esh and Al-Qaeda; previously, sanctions were only on those listed by the UN or by EU countries acting …


UNSC adds 1 to its ISIL (Da’esh) & Al-Qaida sanctions list

The UN Security Council has added Jamal Hussein Hassan Zeiniye to its ISIL (Da’esh) and Al-Qaida sanctions list. He will now be subject to an asset freeze, travel ban and arms embargo. Mr Zeiniye is a leader of the Al-Nusrah Front for the People of the Levant in Syria. In this role, he is said to have participated in armed …


US court dismisses Wael Bazzi’s application for terrorism de-listing

The US District Court for the District of Columbia has granted OFAC’s motion to dismiss a claim brought by Wael Bazzi challenging his designation as a specially designated global terrorist. He was listed in June 2019 for conducting business on behalf of his father, a suspected Hizballah financier (see post). Memorandum Opinion here. The court rejected Mr Bazzi’s Fifth Amendment …


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

Council Implementing Regulation (EU) 2020/1128

Council Implementing Regulation (EU) 2020/1124

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

Council Decision (CFSP) 2020/1126

Council Decision (CFSP) 2020/1132

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

Commission Implementing Regulation (EU) 2020/706

Commission Implementing Regulation (EU) 2020/1473

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

Commission Implementing Regulation (EU) 2020/1297

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)