Taliban, Al Qaeda, ISIL (Da'esh) & Other Terrorist Entities

Information as of: 31st May 2022

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UN S/Res/1267 freezes assets of now deceased Osama Bin Laden, designated associates & companies. Reaffirmed Dec 2009 (S/Res/1904). Urges implementation of Financial Action Task Force’s (FATF) Forty Recommendations on Money Laundering & FATF Nine Special Recommendations on Terrorist Financing. S/Res/2179 (2014), effective 24 Sep 2014, imposes a ban on entry into or transit through a Member State's territory of any individual whom the State has reasonable grounds to believe is seeking entry into or transit through their territory for the purposes of the perpetration, planning, or preparation of, or participation in, terrorist acts or the providing or receiving of terrorist training, and the financing of their travel and of their activities. S/Res/2253 (2015) extends UN asset freeze, travel ban and arms embargo measures to include ISIL (Da'esh) effective 17 Dec 2015. On 17 Dec 2021 all restrictive measures were reaffirmed by 30 months under S/Res/2610 (2021)
US List of sanctioned terrorist entities updated frequently. Dec 2010 - certain exemptions introduced to Global Terrorism Sanctions Regulations & Terrorism Sanctions Regulations for provision of legal services & authorising payments for legal services on behalf of blocked persons. Officials, agents, or affiliates of Iran’s Islamic Revolutionary Guard Corps (IRGC) subject to blocking provisions of GTSR as of 31 Oct 2017. EO12947 was extended until 24 Jan 2020 which prohibits transactions with terrorists who seek to disrupt the Middle East Peace Process. Modernising Sanctions to Combat Terrorism” was introduced, effective 11 Sept 2019, which amends and enhances the powers in Executive Order 13224 (blocking assets of persons who commit, threaten to commit or support terrorism) including secondary sanctions for any “foreign” (non‑U.S.) financial institution that knowingly conducts or facilitates any future “significant transaction” on behalf of any person blocked pursuant to the past and current terrorism-related Executive Orders.OFAC has issued a final rule to remove the Terrorism Sanctions Regulations, 31 CFR part 595 from the Code of Federal Regulations, effective 10 March 2020. These regulations have now been incorporated into EO 13886 “Modernising Sanctions to Combat Terrorism”, issued on 10 September 2019, to form a consolidated counter-terrorism sanctions regime. All restrictive measures under EO 13886 were renewed for a further year until 23 Sept 2021.  OFAC announced that the measures stated originally under EO13224 and amended by EO13886 were renewed again until 23 Sept 2022.
EU The Terrorist Asset-Freezing Act (2010) implements UN Regulation 1373 (2001) and Council Regulation (EU) 2580/2001 in the UK. Sanctions reaffirmed periodically & SDN's & entities on sanctions list regularly amended. CFSP 2016/1693 was renewed by CFSP 2019/1721 until the 31 Oct 2020. Measures stated under (EU)2580/2001 were renewed by adopting Council Implementing Regulation (EU) 2020/19 and (CFSP) 2020/20 Under (CFSP) 2020/1516 all restrictive measures imposed under(CFSP) 2016/1693 were renewed until 31 Oct 2021.  Sanctions originally stated under (EU) 2580/2001 reaffirmed by (EU) 2021/1188. All restrictive measures renewed by (CFSP) 2021/1825 until 31 Oct 2022.
There are three regimes in force in the UK to counter terrorism: 1) The ISIL (Da'esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019 incorporates UN into UK law wef: 31 Dec 2020. 2) The Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019 wef: 31 Dec 2020 specifically replaces the implementation of the EU’s CP931 counter-terrorism sanctions regime and the EU autonomous ISIL (Da’esh) and Al-Qaida regime and also partially gives effect to the UK’s obligations under UN Security Council Resolution 1373 (2001).  3) The Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019 wef: 31 Dec 2020 replaces Part 1 of the Terrorist Asset-Freezing etc.Act 2010 (TAFA). On 11 January 2021, the Treasury revoked 3 general licences which related to the provision of insurance and the payment of legal fees by third parties and can no longer be used. Future applications relating to insurance policies and the payment of legal fees by third parties will be assessed on a case-by-case basis. 
This information has been collated by the International Underwriting Association of London and is intended as a guide only. The IUA does not accept any liability for the accuracy of this information.
This publication is intended to convey only general information about sanctions legislation and associated insurance coverage. It is not, and is not intended to be, a complete statement of the law relating to this area. It should not be relied on or be used as a substitute for legal advice in relation to any particular set of circumstances. Accordingly, IUA does not accept any liability for any loss which may arise from reliance on this information.