EU Council extends sanctions against ISIL/Da’esh and Al-Qaeda until 31 October 2027

On Monday, 26 October, the Council of the European Union extended until 31 October 2027 the autonomous sanctions regime against ISIL/Da’esh, Al-Qaeda and the individuals and groups associated with them. The European list currently includes 15 individuals and eight groups, according to the Council’s statement. The renewal maintains the instruments through which the EU seeks to limit terrorist networks’ access to money and resources and restrict the movement of sanctioned individuals.

In brief, the EU Council renewed for one year, until 31 October 2027, the autonomous sanctions regime against ISIL/Da’esh and Al-Qaeda. The list includes 15 individuals and eight groups. The framework provides for the freezing of funds and economic resources and prohibits making them available to those targeted. Individuals on the list are also subject to entry and transit restrictions. The measures are subject to legal limitations. An exception applies to humanitarian assistance provided by eligible actors, while for the Allied Democratic Forces, the financial measures under this regime are suspended for as long as those under the regime for the Democratic Republic of the Congo apply. The European list complements UN sanctions and must be reviewed at least once every 12 months. The renewal does not mean that all 15 individuals and eight groups were added now.

The decision extends a regime that has been in operation since September 2016 and allows the Union to impose its own sanctions, supplementing those established by the UN Security Council. The new element announced on Monday is the continuation of this framework for another year, not the designation now of all 15 individuals and eight groups.

In practice, the freezing of funds prevents their use, transfer or administration in ways that would allow the money to be used. Economic resources that can be converted into money, goods or services are also blocked. The measure does not, in itself, constitute confiscation of property, and the prohibition on making funds or resources available to those on the list also applies to indirect support.

The regulation covers operations carried out within the Union, nationals of Member States and entities established under the law of a Member State, including when they act outside the EU. For banks and companies, the consequence is that a transaction falling within this scope may not make money or other resources available to a sanctioned beneficiary, except in situations permitted by law.

However, the number of those on the list does not by itself describe all the conditions under which the sanctions apply. For the Allied Democratic Forces, the legal acts provide for the suspension of the freezing of funds and the financing ban under this regime for as long as the group is subject to corresponding measures under the EU regime concerning the Democratic Republic of the Congo. The suspension is conditional on the application of the other regime and does not amount to removing the group from the ISIL/Da’esh and Al-Qaeda list.

Travel restrictions concern the entry and transit of the persons targeted in the territory of the Member States. They do not require a state to refuse entry to its own nationals. Derogations are also possible for urgent humanitarian reasons, judicial proceedings or certain obligations towards international organisations, under the conditions laid down in the decision.

Nor is humanitarian assistance subject to a general prohibition. The regulation exempts funds and resources necessary for the timely provision of assistance or for other activities addressing basic human needs, when carried out by eligible categories. These include the UN, international organisations and certain bilaterally or multilaterally funded NGOs participating in UN humanitarian mechanisms, as well as their partners acting in that capacity. The exception does not automatically cover every transfer described as humanitarian.

Separately, the competent authorities may authorise, under the conditions set by law, the release of certain amounts for basic needs, legal services or other expenses provided for by the regulation. These mechanisms limit the effects of the measures without removing the prohibitions in principle.

The Council presents the sanctions as a tool for preventing the planning, financing and commission of attacks and the dissemination of terrorist propaganda. The statement does not quantify the funds blocked or attacks prevented by this renewal, so maintaining the regime alone does not provide a measure of its effectiveness.

Autonomous measures must be reviewed periodically, at least once every 12 months. Those on the list must be given the reasons for their designation and may submit observations, while the Council must reconsider the decision when it receives such observations or substantial new evidence. The 2027 deadline does not remove this review obligation.