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Date: 19-Feb-2025 Category: Not Applicable State: Union Government Country: Europe

Council Decision (CFSP) 2025/336 of 18 February 2025 amending Decision (CFSP) 2016/1693 concerning restrictive measures against ISIL (Da’esh) and Al-Qaeda and persons, groups, undertakings and entities associated with them

Issued by Council of the European Union · Not Applicable

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Executive Summary & Key Takeaways

What it means

  • Council Decision (CFSP) 2025/336 amends Decision (CFSP) 2016/1693 concerning restrictive measures against ISIL (Da’esh) and Al-Qaeda, and associated persons, groups, undertakings, and entities. The amendment ensures the continuation of a humanitarian exemption to the sanctions regime.

Key Changes

  • Article 6, paragraph 2 of Decision (CFSP) 2016/1693 is deleted.
  • The humanitarian exemption, initially introduced by UNSC Resolution 2664 (2022) and previously extended by Council Decision (CFSP) 2023/726 until December 9, 2024, is continued following UNSC Resolution 2761 (2024).
  • This decision enters into force on the day following its publication in the Official Journal of the European Union.

Impact Analysis

Humanitarian Organizations

  • Action Items: Humanitarian organizations should remain aware of the scope and limitations of the humanitarian exemption and ensure compliance with relevant regulations and reporting requirements.

Financial Institutions

  • Action Items: Financial institutions should update their compliance procedures to reflect the continued humanitarian exemption and ensure that transactions related to humanitarian assistance are properly screened and processed.

Governments and Regulatory Bodies

  • Action Items: Governments should update national legislation and guidance to reflect the changes in the EU sanctions regime. Regulatory bodies should communicate these changes to relevant stakeholders.

Businesses and Individuals

  • Action Items: Businesses and individuals should familiarize themselves with the updated sanctions regime and ensure that their activities comply with the humanitarian exemption.

Key Entities Referenced

Council of the European Union: The institution of the European Union that adopted Decision (CFSP) 2025/336. ISIL (Da’esh) and Al-Qaeda: The terrorist organizations targeted by the restrictive measures. United Nations Security Council (UNSC): The UN body that adopted Resolutions 2664 (2022) and 2761 (2024), which established and extended the humanitarian exemption. Decision (CFSP) 2016/1693: The original Council Decision concerning restrictive measures against ISIL (Da’esh) and Al-Qaeda. Decision (CFSP) 2023/726: The Council Decision that previously amended Decision (CFSP) 2016/1693 to incorporate the humanitarian exemption until December 9, 2024.
Official Source Record View Original Source →
See Full Document Text
Official Journal EN of the European Union L series 2025/336 19.2.2025 COUNCIL DECISION (CFSP) 2025/336 of 18 February 2025 amending Decision (CFSP) 2016/1693 concerning restrictive measures against ISIL (Da’esh) and Al-Qaeda and persons, groups, undertakings and entities associated with them THE COUNCIL OF THE EUROPEAN UNION, Having regard to the Treaty on European Union, and in particular Article 29 thereof, Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy, Whereas: (1) On 20 September 2016, the Council adopted Decision (CFSP) 2016/1693 (1). (2) On 9 December 2022, the United Nations Security Council (UNSC) adopted Resolution 2664 (2022). In that Resolution, the UNSC decided that the provision, processing or payment of funds, other financial assets or economic resources or the provision of goods and services necessary to ensure the timely delivery of humanitarian assistance or to support other activities that support basic human needs are permitted and are not a violation of the asset freezes imposed by the UNSC or its Sanctions Committees. In Resolution 2664 (2022), the UNSC also decided that the humanitarian exemption will apply to the ISIL (Da’esh) and Al-Qaeda sanctions regime for a period of two years from the date of adoption of that Resolution. (3) On 31 March 2023, the Council adopted Decision (CFSP) 2023/726 (2), which amended Decision (CFSP) 2016/1693 to introduce the humanitarian exemption established by the UNSC in Resolution 2664 (2022), which would apply until 9 December 2024, unless the UNSC decided to extend its application beyond that date. (4) On 6 December 2024, the UNSC adopted Resolution 2761 (2024) and decided that the humanitarian exemption introduced by Resolution 2664 (2022) should continue to apply to the ISIL (Da’esh) and Al-Qaeda sanctions regime. (5) Decision (CFSP) 2016/1693 should therefore be amended accordingly, HAS ADOPTED THIS DECISION: Article 1 In Article 6 of Decision (CFSP) 2016/1693, paragraph 2 is deleted. Article 2 This Decision shall enter into force on the day following that of its publication in the Official Journal of the European Union. Done at Brussels, 18 February 2025. For the Council The President A. DOMAŃSKI (1) Council Decision (CFSP) 2016/1693 of 20 September 2016 concerning restrictive measures against ISIL (Da’esh) and Al-Qaeda and persons, groups, undertakings and entities associated with them and repealing Common Position 2002/402/CFSP (OJ L 255, 21.9.2016, p. 25, ELI: http://data.europa.eu/eli/dec/2016/1693/oj). (2) Council Decision (CFSP) 2023/726 of 31 March 2023 amending certain Council Decisions concerning restrictive measures in order to insert provisions on a humanitarian exemption (OJ L 94, 3.4.2023, p. 48, ELI: http://data.europa.eu/eli/dec/2023/726/oj). ELI: http://data.europa.eu/eli/dec/2025/336/oj 1/1

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