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.
On 25th April 2024, the Security Council ISIL (Da’esh) and Al-Qaida Sanctions Committee amended one entry on its sanctions list.
Sanction Name
UN Sanctions Against Afghanistan
First Imposed
Last updated
Targets
Asset Freeze and Travel Ban:
• Members or associates of the Taliban or Al-Qaeda
Arms Embargo:
• Members or associates of the Taliban or Al-Qaeda
Exemptions
1. The UN legislation allows for some exemptions to an asset freeze for an individual to meet with the ombudsman to challenge inclusion on the sanctions list.
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.
Links 1
Sanction Name
EU Sanctions Against Afghanistan
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze and Travel Ban:
• Members or associates of the Taliban or Al-Qaeda
Arms Embargo:
• Members or associates of the Taliban or Al-Qaeda
Exemptions
1. Asset Freeze exemptions are permitted for certain legal and basic expenses.
On 11th February 2024 the US extended Executive Order 14064 regarding the situation in Afghanistan for a year until 11th February 2025.
Sanction Name
US Sanctions against Afghanistan
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze and Travel Ban:
• Members or associates of the Taliban or Al-Qaeda
Arms Embargo:
• Members or associates of the Taliban or Al-Qaeda
Exemptions
1. Individuals subject to travel bans are permitted entry or transit when participating in judicial processes or when travelling to their country of nationality.
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, as long as these do not constitute luxury goods or 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.
Links 1
Sanction Name
The Afghanistan (Sanctions) (EU Exit) Regulations 2020
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze and Travel Ban:
• Members or associates of the Taliban or Al-Qaeda
Arms Embargo:
• Members or associates of the Taliban or Al-Qaeda
Exemptions
1. Asset Freeze exemptions are permitted for certain legal and basic expenses.
