Overview
UN Sanctions
UN sanctions were initially imposed in 1999, in response to actions of the Taliban, including providing sanctuary and training for international terrorist groups. In 2000, sanctions consisted of travel bans and asset freezes of Osama bin Laden and associates and an arms embargo on Afghanistan. In 2011, the UN separated listings for the Taliban and its supporters from those for al-Qaida and Daesh, which remain under the ISIL (Da’esh) and Al Qaida sanctions regime. Current UN sanctions on Afghanistan, consisting of asset freezes, travel bans, and an arms embargo, are overseen by the 1988 Sanctions Committee and are imposed pursuant to UN Security Council Resolution 1988.
EU Sanctions
The EU implemented UN sanctions relating to Afghanistan in 1999 by Council Common Position 1999/727/CFSP, followed by Council Regulation (EC) No 337/2000. In 2011, the EU implemented the split in UN sanctions. It implemented the Afghanistan specific sanctions, which target the Taliban, under Council Regulation (EU) No 753/2011 and Council Decision 2011/486/CFSP, and repurposed the existing regime (Council Regulation (EC) No 881/2002) to target only Al-Qaida. The EU does not impose its own autonomous sanctions on Afghanistan.
UK Sanctions
On 1 January 2021, at the end of the Brexit transition period, The Afghanistan (Sanctions) (EU Exit) Regulations 2020 came into force in the UK. The UK regulations give effect to the UK’s UN obligations and substantially have the same effect as the EU regime.
US Sanctions
The US first implemented sanctions on Afghanistan in 2001 via EO 13224 which created a national emergency with respect the Taliban. This was terminated in 2002 pursuant to EO 13268 and certain exceptions were introduced for property of Da Afghanistan Bank in 2022 by EO 14064.
Current UN Sanctions
UN sanctions were initially imposed in 1999, in response to actions of the Taliban, including providing sanctuary and training for international terrorist groups. In 2000, sanctions consisted of travel bans and asset freezes of Osama bin Laden and associates and an arms embargo on Afghanistan. In 2011, the UN separated listings for the Taliban and its supporters from those for al-Qaida and Daesh, which remain under the ISIL (Da’esh) and Al Qaida sanctions regime. Current UN sanctions on Afghanistan, consisting of asset freezes, travel bans, and an arms embargo, are overseen by the 1988 Sanctions Committee and are imposed pursuant to UN Security Council Resolution 1988.
Current EU Sanctions
The EU implemented UN sanctions relating to Afghanistan in 1999 by Council Common Position 1999/727/CFSP, followed by Council Regulation (EC) No 337/2000. In 2011, the EU implemented the split in UN sanctions. It implemented the Afghanistan specific sanctions, which target the Taliban, under Council Regulation (EU) No 753/2011 and Council Decision 2011/486/CFSP, and repurposed the existing regime (Council Regulation (EC) No 881/2002) to target only Al-Qaida. The EU does not impose its own autonomous sanctions on Afghanistan.
Current UK Sanctions
On 1 January 2021, at the end of the Brexit transition period, The Afghanistan (Sanctions) (EU Exit) Regulations 2020 came into force in the UK. The UK regulations give effect to the UK’s UN obligations and substantially have the same effect as the EU regime.
Current US Sanctions
The US first implemented sanctions on Afghanistan in 2001 via EO 13224 which created a national emergency with respect the Taliban. This was terminated in 2002 pursuant to EO 13268 and certain exceptions were introduced for property of Da Afghanistan Bank in 2022 by EO 14064.
- Legislation
EO 14064 Protecting Certain Property of Da Afghanistan Bank for the Benefit of the People of Afghanistan (February 11, 2022)
EO 13268 Termination of Emergency With Respect to the Taliban and Amendment of Executive Order 13224 of September 23, 2001 (July 2, 2002)
EO 13224 Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism (Effective Date – September 24, 2001)
- Sanctions List
Search “Afghanistan” on the OFAC SDN List
- Guidance
- US General Licences
General License 14 – Authorizing Humanitarian Activities in Afghanistan (September 24, 2021)
General License 15 – Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates in Afghanistan (September 24, 2021)
General License 16 – Authorizing Noncommercial, Personal Remittances to Afghanistan (December 10, 2021)
General License 17 – Authorizing Official Business of the United States Government (December 22, 2021)
General License 18 – Authorizing Official Activities of Certain International Organizations and Other International Entities (December 22, 2021)
General License 19 – Authorizing Certain Transactions in Support of Nongovernmental Organizations’ Activities in Afghanistan (December 22, 2021)
General License 20 – Authorizing Transactions Involving Afghanistan or Governing Institutions in Afghanistan (February 25, 2022)
- Judgments
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Rahmani v Janet Yellen Civil Action No: 24-0285 (RC)
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Other Countries Sanctions
- Judgments
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Yasin Qadi v Prime Minister of Turkey Judgment No. 2006/4795
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