Date: 2025-10-16Category: Not ApplicableState: Union GovernmentCountry: Europe
Commission Implementing Regulation (EU) 2025/2123 of 14 October 2025 amending for the 350th time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da’esh) and Al-Qaida organisations
**Executive Summary**
This Commission Implementing Regulation (EU) 2025/2123, dated October 14, 2025, amends Council Regulation (EC) No 881/2002. It updates Annex I to reflect decisions by the UN Security Council Sanctions Committee regarding persons, groups, and entities subject to fund-freezing measures related to ISIL (Da'esh) and Al-Qaida. The regulation enters into force the day following its publication in the Official Journal of the European Union.
**Key Points / Main Content**
* **Amendment of Annex I:**
* Annex I to Regulation (EC) No 881/2002 is amended according to the Annex of this new regulation.
* This change reflects the UN Security Council’s decision on October 6, 2025, to amend entries in the list of persons, groups, and entities subject to fund-freezing measures.
* **Specific Updates to Annex I:**
* The entry for "Abd El Kader Mahmoud Mohamed El Sayed" is replaced with updated identifying information, including a note that he was reportedly killed in the border region of Afghanistan and Pakistan in 2012.
* The entry for "Aris Sumarsono" is replaced with updated information, including a note that he was sentenced to 15 years in prison in Indonesia in January 2022.
* **Enforcement:**
* The regulation is binding in its entirety and directly applicable in all Member States.
**Impact Analysis**
**Member States**
* **Impact**: Member States are obligated to implement the updated fund-freezing measures against the individuals and entities listed in the amended Annex I.
* **Action Required**: Member States must update their national regulations and enforcement procedures to reflect the changes in Annex I and ensure compliance.
**Listed Individuals/Entities**
* **Impact**: The listed individuals and entities, specifically "Abd El Kader Mahmoud Mohamed El Sayed" and "Aris Sumarsono," are subject to continued fund-freezing measures, with updated information reflecting current status (e.g., reported death, imprisonment).
* **Action Required**: They have no direct action required, but may challenge these measures through legal channels if applicable.
**Financial Institutions**
* **Impact**: Financial institutions within the EU must screen their accounts and transactions against the updated list of designated individuals and entities.
* **Action Required**: They must freeze any assets held by these individuals/entities and report such assets to the relevant authorities.
Key Entities Referenced
Council Regulation (EC) No 881/2002: The primary regulation being amended, which imposes restrictive measures against individuals and entities associated with ISIL (Da'esh) and Al-Qaida organizations.
Annex I to Regulation (EC) No 881/2002: The specific part of Regulation 881/2002 being amended, listing persons, groups and entities subject to the freezing of funds and economic resources.
ISIL (Da'esh) and Al-Qaida organisations: Organizations against whom the restrictive measures are directed.
European Commission: The issuing authority of the implementing regulation.
United Nations Security Council Resolutions 1267(1999), 1989(2011) and 2253(2015): Resolutions upon which the Sanctions Committee’s decisions were based.
Official Journal EN
of the European Union L series
2025/2123 16.10.2025
COMMISSION IMPLEMENTING REGULATION(EU) 2025/2123
of 14 October 2025
amending for the 350th time Council Regulation (EC) No 881/2002 imposing certain specific
restrictive measures directed against certain persons and entities associated with the ISIL (Da’esh)
and Al-Qaida organisations
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Council Regulation (EC) No 881/2002 of 27 May 2002 imposing certain specific restrictive measures
directed against certain persons and entities associated with the ISIL (Da’esh) and Al-Qaida organisations(1), and in
particular Article 7(1), point (a), and Article 7a(5) thereof,
Whereas:
(1) Annex I to Regulation (EC) No 881/2002 lists the persons, groups and entities covered by the freezing of funds and
economic resources under that Regulation.
(2) On 6 October 2025, the Sanctions Committee of the United Nations Security Council established pursuant to UN
Security Council Resolutions 1267(1999), 1989(2011) and 2253(2015) decided to amend two entries in the list of
persons, groups and entities to whom the freezing of funds and economic resources should apply.
(3) Annex I to Regulation (EC) No 881/2002 should therefore be amended accordingly,
HAS ADOPTED THIS REGULATION:
Article 1
Annex I to Regulation (EC) No 881/2002 is amended in accordance with the Annex to this Regulation.
Article 2
This Regulation shall enter into force on the day following that of its publication in the Official Journal of the European Union.
This Regulation shall be binding in its entirety and directly applicable in all Member States.
Done at Brussels, 14 October 2025.
For the Commission,
On behalf of the President,
Director-General
Directorate-General for Financial Stability, Financial
Services and Capital Markets Union
(1) OJ L 139, 29.5.2002, p. 9, ELI: http://data.europa.eu/eli/reg/2002/881/oj.
ELI: http://data.europa.eu/eli/reg_impl/2025/2123/oj 1/2EN
OJ L, 16.10.2025
ANNEX
The identifying data for the following entries under the heading ‘Natural persons’ in Annex I to Regulation (EC)
No 881/2002 is amended as follows:
(1) ‘Abd El Kader Mahmoud Mohamed El Sayed (alias (a) Es Sayed, Kader, (b) Abdel Khader Mahmoud Mohamed el
Sayed). Date of birth: 26.12.1962. Place of birth: Egypt. Nationality: Egyptian. Other information: (a) Italian Fiscal
Code: SSYBLK62T26Z336L, (b) Considered a fugitive from justice by the Italian authorities. Date of designation
referred to in Article 2a (4)(b): 24.4.2002.’
is replaced by the following:
‘Abd El Kader Mahmoud Mohamed El Sayed (original script: ﺪﯿﺴﻟاﺪﻤﺤﻣدﻮﻤﺤﻣردﺎﻘﻟاﺪﺒﻋ) (good quality alias: (a) Es Sayed,
Kader; (b) Abdel Khader Mahmoud Mohamed el Sayed). Date of birth: 26.12.1962. Place of birth: Egypt. Nationality:
Egyptian. Other information: (a) Italian Fiscal Code: SSYBLK62T26Z336L; (b) Considered a fugitive from justice by
the Italian authorities;(c) Reportedly killed in the border region of Afghanistan and Pakistan in 2012. Date of
designation referred to in Article 7d(2)(i): 24.4.2002.’
(2) ‘Aris Sumarsono (good quality alias (a) Zulkarnan, (b) Zulkarnain, (c) Zulkarnin, (d) Arif Sunarso, (e) Zulkarnaen, (f)
Aris Sunarso, (g) Ustad Daud Zulkarnaen; low quality alias (a) Murshid, (b) Daud, (c) Pak Ud, (d) Mbah Zul, (e) Zainal
Arifin, (f) Zul, (g) Abdullah Abdurrahman, (h) Abdul, (i) Abdurrahman). Date of birth: 19.4.1963. Place of birth:
Gebang village, Masaran, Sragen, Central Java, Indonesia. Nationality: Indonesian. Address: (a) Desa Gebang,
Kecamatan Masaran, Kabupaten Sragen, Jawa Tengah, Indonesia, (b) Desa Taman Fajar, Kecamatan Probolinggo,
Kabupaten Lampung Timur, Lampung, Indonesia. Date of designation referred to in Article 7d(2)(i): 16.5.2005.’
is replaced by the following:
‘Aris Sumarsono (good quality alias: (a) Zulkarnan; (b) Zulkarnain; (c) Zulkarnin; (d) Arif Sunarso; (e) Zulkarnaen;
(f) Aris Sunarso; (g) Ustad Daud Zulkarnaen; low quality alias: (a) Murshid; (b) Daud; (c) Pak Ud; (d) Mbah Zul;
(e) Zainal Arifin; (f) Zul; (g) Abdullah Abdurrahman; (h) Abdul; (i) Abdurrahman). Date of birth: 19.4.1963. Place of
birth: Gebang village, Masaran, Sragen, Central Java, Indonesia. Nationality: Indonesian. Address: (a) Desa Gebang,
Kecamatan Masaran, Kabupaten Sragen, Jawa Tengah, Indonesia; (b) Desa Taman Fajar, Kecamatan Probolinggo,
Kabupaten Lampung Timur, Lampung, Indonesia. Other information: He was sentenced to 15 years in prison in
Indonesia in January 2022. Date of designation referred to in Article 7d(2)(i): 16.5.2005.’
2/2 ELI: http://data.europa.eu/eli/reg_impl/2025/2123/oj