ISIL (Da'esh) and Al-Qaida financial sanctions: list of asset-freeze targets
Source: gov.uk (2025-11-07)

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

The ISIL (Da’esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019, which ensure sanctions under the UN sanctions regime in respect of ISIL (Da’esh) and Al-Qaida continue to be implemented effectively, came into force at 11pm on 31 December 2020.

Context

This sanctions regime imposes certain measures against those named on the UN’s ISIL (Da’esh) and Al-Qaida Sanctions List.

This regime is one of three of the UK’s counter-terrorism sanctions regimes which will be in place after the end of the transition period: the other two sanctions regimes relating to counter-terrorism are the Counter-Terrorism (Sanctions) (EU Exit) regime and the Counter-Terrorism (International Sanctions) (EU Exit) regime.

Counter-Terrorism Licensing Policy

Licences authorise certain activities or types of transaction that would otherwise be prohibited by asset freezing legislation. In addition to issuing licences relating to a specific person, the Treasury may also issue general licences, which authorise otherwise prohibited activity by a particular category of persons (who fall within the licence criteria). For further details on the Treasury’s approach to licensing, see counter-terrorism licensing policy. (https://www.gov.uk/government/publications/counter-financing-of-terrorism-general-licenses)

UN resolutions

UN Security Resolution 2368 (2017) currently imposes the asset freeze, travel ban and arms embargo affecting all individuals and entities named on the ISIL (Da’esh) & Al-Qaida Sanctions List.

The resolution notes that the asset freeze requirements apply to financial transactions involving any funds, economic resources or income-generating activities that benefit individuals, groups, undertakings and entities on the ISIL (Da’esh) & Al-Qaida Sanctions List, including, but not limited to, trade in petroleum products, natural resources, chemical or agricultural products, weapons, or antiquities by listed individuals, groups, undertakings and entities, kidnapping for ransom, and the proceeds of other crimes including, trafficking in persons, extortion and bank robbery.

UK Regulations

The ISIL (Da’esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019 (https://www.legislation.gov.uk/uksi/2019/466/introduction/made)

The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2019 (https://www.legislation.gov.uk/uksi/2019/843/contents/made)

The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2020 (https://www.legislation.gov.uk/uksi/2020/591/contents/made)

The Sanctions (EU Exit) (Miscellaneous Amendments) (No.3) Regulations 2020 (https://www.legislation.gov.uk/uksi/2020/950/contents/made)

The ISIL (Da’esh) and Al-Qaida (Asset-Freezing) Regulations 2011 (as amended) (https://www.legislation.gov.uk/uksi/2011/2742/contents/made) (applicable prior to 11pm on 31 December 2020) .

EU Regulations (applicable prior to 11pm on 31 December 2020)

EU Regulation 881/2002 (https://www.legislation.gov.uk/eur/2002/881)

Usama bin Laden

On 21 February 2013, the UN decided to remove Usama bin Laden from their sanctions list.

Instead there is now a separate process for unfreezing funds owned or controlled by Bin Laden (see paragraph 32 of UNSCR 2083 (2012)). (https://documents-dds-ny.un.org/doc/UNDOC/GEN/N12/652/82/PDF/N1265282.pdf?OpenElement)

To implement this, regulation 25 of the ISIL(Da’esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019 imposes a prohibition that a person must not deal with the funds or economic resources owned, held or controlled by, Usama bin Laden at the time of his death, or which after his death formed all or part of his estate, if that person knows, or has reasonable cause to suspect, that they are dealing with such funds or economic resources.

Accordingly, his assets remain frozen and an application must be made, and approved by the UN Security Council’s Sanctions Committee, to unfreeze them.

Find out more about UK sanctions on ISIL (Da’esh) and Al-Qaida organisations (https://www.gov.uk/government/collections/uk-sanctions-on-isil-daesh-and-al-qaida)