Background
Sanctions were first imposed by the UN in 1999, targeting individuals involved in the Taliban Government, which administered the country from 1996 until 2001. Subsequent programmes, instituted following the US-led invasion of the country in 2001, have targeted insurgent groups tied to the Taliban and parties deemed to be close to Al-Qaeda. No further sanctions have been imposed on the Taliban or Afghanistan’s government since the Taliban restored control over the country in August 2021 and legislation has since been introduced to facilitate certain interactions with the country.
Sanctioning Bodies
Active Sanctions Programmes
UN
UN Sanctions Against Afghanistan
• Members or associates of the Taliban or Al-Qaeda
Arms Embargo:
• Members or associates of the Taliban or Al-Qaeda
2. Individuals are permitted to travel to other jurisdictions for the fulfilment of judicial processes.
3. On 23rd December 2021 the UN Security Council unanimously adopted resolution 2615, which establishes an exemption from Taliban-related sanctions for humanitarian assistance and other activities that support basic needs in Afghanistan.
OFAC
US Sanctions Against Afghanistan
• Members or associates of the Taliban or Al-Qaeda
Arms Embargo:
• Members or associates of the Taliban or Al-Qaeda
2. Asset freeze exemptions are considered on a case-by-case basis for certain expenses.
3. On 24th September 2021 the US issued a General Licence permitting the export to Afghanistan of agricultural commodities, medicine, medical devices, replacement parts and components, as well as software updates.
4. On 10th December 2021 OFAC issued General License 16, which authorises transactions involving the Taliban or the Haqqani Network that are necessary to the transfer of non-commercial personal remittances to Afghanistan.
5. On 22nd December 2021 OFAC issued General Licenses 17, 18 and 19, adding exemptions for personal remittances and for the provision of humanitarian assistance to a range of civil society bodies under the control of the Taliban or Haqqani network.
6. On 25th February 2022 OFAC issued General License 20, which authorises transactions involving Afghanistan and/or governing institutions in Afghanistan. However, the license does not permit: a) financial transfers to the Taliban, Haqqani Network or any entity involved in either organisation, b) any person who is a leader of either organisation who is blocked under existing sanctions regulations (with some exemptions for the payment of taxes or import duties and public utility services) c) any debit to the US account of a blocked person, or d) transactions with any person who is personally sanctioned, unless separately authorised.
- OFAC Afghanistan-Related Sanctions
- Executive Order 13224 – Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism (24/09/2001)
- Executive Order 13268 – Termination of Emergency With Respect to the Taliban and Amendment of Executive Order 13224 of September 23, 2001 (02/07/2002)
- Executive Order 14064 – Protecting Certain Property of Da Afghanistan Bank for the Benefit of the People of Afghanistan (11/02/2022)
EU
EU Sanctions Against Afghanistan
• Members or associates of the Taliban or Al-Qaeda
Arms Embargo:
• Members or associates of the Taliban or Al-Qaeda
OFSI
The Afghanistan (Sanctions) (EU Exit) Regulations 2020
• Members or associates of the Taliban or Al-Qaeda
Arms Embargo:
• Members or associates of the Taliban or Al-Qaeda
SECO
Measures Against Entities and Persons Linked to the Taliban
• Persons and entities linked to the Taliban. This programme includes a prohibition on the supply of arms and related material and travel bans.