Sanctions programmes targeting Libya began with the country’s 2011 civil war, which saw extensive human rights abuses committed under the government of then-head of state Muammar Gaddafi. Since Gaddafi’s removal programmes remain in place targeting individuals involved in offences during the conflict and preventing the misappropriation of frozen government assets.
On 2nd June 2023 the UN Security Council extended its Libya Sanctions Program until 2nd June 2024.
On 29th November 2023 the UN granted a humanitarian travel exemption, valid for six months, to two sanctioned individuals. The same day, the UN amended five entries to the Libya sanctions list.
On 31st January 2024 the UN removed the travel ban on Safia Farkash Al-Barassi, who was granted a six-month humanitarian travel exemption in November 2023. She is still subject to an asset freeze.
Sanction Name
United Nations Security Council Regulations Against Libya
First Imposed
Last updated
Targets
Arms Embargo and Trade Restrictions:
• Controls on the export of arms or related material to Libya, including a ban on the provision of such items to any recipient apart from the Libyan government.
• Measures against the unlicensed sale of Libyan crude oil and vessels determined to be transporting such.
Asset Freeze and Travel Ban:
• Officials of the former government of the late Muammar Gaddafi who have been implicated in violence against civilians, members of armed groups involved in attacks on infrastructure or foreign missions and the financial supporters of such groups.
Exemptions
1. Arms supplied for use by the Libyan Government; non-lethal equipment intended solely for humanitarian or protective use; or small arms and related material for certain actors is exempt from sanctions, following prior notification to the UN Sanctions Committee.
2. Travel ban exemptions are also in place for travel on humanitarian grounds, the fulfilment of judicial processes or to advance peace and stability in Libya.
3. There is also an exemption on frozen assets with regards to judicial, administrative or arbitral liens or judgments as well as on interests, earnings and payments due under contracts, agreements or obligations entered into prior to the listing of a sanctioned party or for humanitarian purposes.
4. The provision of bunkering services to designated vessels is authorised if it is necessary for humanitarian purposes as is the entry into Libyan ports in the case of emergency.
Sanction Name
Council Regulation Concerning Restrictive Measures In View Of The Situation In Libya
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze, Arms Embargo and Trade Restrictions:
• Individuals deemed to be posing a risk to the country’s transition to peacetime government following the conclusion of its 2011 civil war, especially those associated with the government of the late former Head of State Muammar Gaddafi or those benefiting from embezzled state funds.
• The programme includes trade restrictions to support these aims, including a ban on the export to Libya of arms or related materiel to any recipients except the government or UN peacekeepers and a prohibition on the loading, transportation or discharge of petroleum products illicitly exported or attempted to be exported from Libya.
• Some restrictions aimed at combating the trade in illegally exported crude oil and restricting the use of economic resources previously controlled by the Gaddafi government. The programme also prohibits the importation of arms from Libya.
Exemptions
1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or to facilitate the attendance of inter-governmental meetings.
2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.
Sanction Name
Order Establishing Measures Against Libya
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze, Arms Embargo and Travel Ban:
• The family of the late Muammar Gaddafi, senior officials in his government and any individuals deemed to be responsible for or complicit in human rights abuses during the 2011 Libyan Civil War or to have materially assisted in these abuses. This includes an embargo on the sale of arms to such parties or the purchase of arms from Libya.
Exemptions
1. Non-lethal equipment intended solely for humanitarian or protective use and hunting or sporting weapons are exempt.
2. Asset freeze exemptions apply to prevent cases of rigor, in respect of existing contracts, to respect credits due under existing judicial, administrative or arbitral judgments, for humanitarian purposes, to finance economic reconstruction or to protect Swiss interests.
3. Travel ban exemptions may be granted on humanitarian grounds or for the attendance of international conferences, participation in political dialogue concerning Libya or if the protection of Swiss interests requires it.
Sanction Name
Regulations Against Certain Transactions Related to Libya
SANCTIONS
First Imposed
Last updated
Targets
Specially Designated National and Travel Ban:
• The family of the late Muammar Gaddafi, senior officials in his government and any individuals deemed to be responsible for or complicit in human rights abuses during the Libyan Civil War, or who have been engaged in actions or policies that threaten the peace in Libya, have resulted in the misappropriation of Libyan state assets or threaten Libyan state financial institutions or the Libyan National Oil Company.
Exemptions
1. Through eight General Licences, OFAC authorises all transactions with the Government of Libya, the Transitional National Council of Libya and 21 state agencies. Transactions involving Qatar Petroleum or Vitol relating to oil, gas and petroleum products exported from Libya are authorised, while US persons are authorised to continue operating investment funds in which the Government of Libya has both a non-controlling and minority interest.
Sanction Name
Libya (Sanctions) (EU Exit) Regulations 2020
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze, Arms Embargo and Trade Restrictions:
• Individuals deemed to pose a risk to the country’s transition to peacetime government following the conclusion of its 2011 civil war, especially those associated with the government of the late former Head of State Muammar Gaddafi or those benefiting from embezzled state funds.
• The programme includes trade restrictions to support these aims, including a ban on the export to Libya of arms or related materiel to any recipients except the government or UN peacekeepers and a prohibition on the loading, transportation or discharge of petroleum products illicitly exported or attempted to be exported from Libya.
• Some restrictions aimed at combating the trade in illegally exported crude oil and restricting the use of economic resources previously controlled by the Gaddafi government. The programme also prohibits the importation of arms from Libya.
Exemptions
1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or associated with the attendance of inter-governmental meetings.
2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.
