Financial sanctions, ISIL (Da'esh) and Al-Qaida organisations

Certain persons and entities associated with the ISIL (Da'esh) and Al-Qaida organisations are subject to financial sanctions.


UN Security Council Resolution 1267 (1999)

This resolution (and its successor resolutions) requires all member states to take the following action against individuals and organisations associated with ISIL (Da’esh) and Al-Qaida, and Usama bin Laden/the Taliban:

  • freeze assets
  • prevent entry into/transit through their territories
  • prevent the direct or indirect supply, sale and transfer of arms and military equipment

UN Security Council Resolution 1988 (2011)

This split the sanctions regime into two groups:

UN Security Resolution 2253 (2015)

This renamed the Al-Qaida Sanctions List, the ‘ISIL (Da’esh) and Al-Qaida Sanctions List’. It also ensures that individuals and organisations supporting ISIL (Da’esh) are eligible for listing by the UN (also under EU in Regulation 2016/363).

EU Regulation (2016/1686)

Implemented on 22 September 2016, this permits the EU to make autonomous Al-Qaida and ISIL (Da’esh) listings.

EU autonomous listings are included in the ‘ISIL (Da’esh) and Al-Qaida Organisations’ section of the UK’s consolidated list and can be identified by the text ‘EU listing only’ in the ‘Other Information’ field.

EU Regulation (881/2002)

UN measures are implemented in the EU by Council Regulation (EC) No 881/2002.

EU Regulations 881/2002 and 2016/1686 are enforced in the UK by the ISIL (Da’esh) and Al-Qaida (Asset-Freezing) Regulations 2011 (S.I. 2011/2742 as renamed by S.I. 2016/937).

There are a number of differences between the Al-Qaida and ISIL regimes (see EU Regulations 881/2002 and 2016/1686).

Usama bin Laden

On 21 February 2013, the UN decided to remove Usama bin Laden from their financial sanctions list (following resolutions 1267(1999) and 1989(2011)).

They imposed a separate process for unfreezing funds owned or controlled by Bin Laden (in line with paragraph 32 of UNSCR 2083 (2012).

To implement this, the EU adopted Regulation 596/2013 which:

  • removed Bin Laden from Annex I to EU Regulation 881/2002
  • added him to a separate annex, Annex Ia of the same regulations (Usama Bin Laden is currently the only entry in that Annex)

As part of this change, his funds remain frozen and any attempt to unfreeze these assets requires approval by the UN Security Council’s Sanctions Committee.

However, making funds available to individuals or entities listed in Annex Ia is no longer prohibited.

Current EU regulations

Current UK legislation

  • the Al Qaida (Asset Freezing) (Amendment) Regulations 2016 (S.I. 2016/937). This amended the Al-Qaida (Asset-Freezing) Regulations 2011 (S.I. 2011/2742) to incorporate changes made by EU Regulation 2016/363 (to incorporate changes adopted by UNSCR 2253 (2015), which ensured, amongst other things, that persons or entities supporting ISIL (Da’esh) are eligible for listing by the UN) and EU Regulation 2016/1686 (the EU autonomous listing component)

  • the Al-Qaida (Asset-Freezing) Regulations 2011 is the original enforcement Regulation (this version does not show the amendments made by S.I. 2016/937)

  • the consolidated Regulation (The ISIL (Da’esh) and Al-Qaida (Asset-Freezing) Regulations 2011 (S.I. 2011/2742 as renamed by S.I. 2016/937)) that makes provision for enforcing EU Council Regulations 881/2002 and 2016/1686, will be made available on in due course