Home Europe Council of the European Union Council Implementing Regulation (EU) 2025/2401 of 24 Novembe...
Date: 2025-11-24 Category: Not Applicable State: Union Government Country: Europe

Council Implementing Regulation (EU) 2025/2401 of 24 November 2025 implementing Regulation (EU) 2016/1686 imposing additional restrictive measures directed against ISIL (Da’esh) and Al-Qaeda and natural and legal persons, entities or bodies associated with them

Issued by Council of the European Union · Not Applicable

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Executive Summary & Key Takeaways

**Executive Summary** Council Implementing Regulation (EU) 2025/2401, dated 24 November 2025, amends Regulation (EU) 2016/1686, which imposes restrictive measures against ISIL (Da'esh), Al-Qaeda, and associated individuals and entities. The amendment adds one entity to the list in Annex I of Regulation (EU) 2016/1686. This regulation enters into force upon its publication in the Official Journal of the European Union. **Key Points / Main Content** * **Amendment to Regulation (EU) 2016/1686:** * Annex I of Regulation (EU) 2016/1686 is amended. * One entity is added to the list of natural and legal persons, entities, and bodies associated with ISIL (Da'esh) and Al-Qaeda. * **Addition to Annex I:** * Under the heading "B. Legal persons, entities and bodies referred to in Article 3," the following entry is added: "8. Allied Democratic Forces." * **Entry into Force:** * This Regulation shall enter into force on the date of its publication in the Official Journal of the European Union. **Impact Analysis** **EU Member States** * **Impact:** The regulation is binding in its entirety and directly applicable in all Member States, implying that they must implement the added restrictive measures against the newly listed entity. * **Action Required:** Update and enforce sanctions regimes to include the "Allied Democratic Forces." **Allied Democratic Forces** * **Impact:** The entity "Allied Democratic Forces" is subject to the restrictive measures imposed by Regulation (EU) 2016/1686, which may include asset freezes, travel bans, and other restrictions. * **Action Required:** N/A. The regulation imposes restrictions, it does not require any action from them. **Entities and Individuals dealing with the Allied Democratic Forces** * **Impact:** Any entities and individuals who interact with the Allied Democratic Forces may be subject to the restrictive measures imposed by Regulation (EU) 2016/1686 * **Action Required:** Conduct appropriate due diligence in order to comply with the Regulation.

Key Entities Referenced

Regulation (EU) 2016/1686: Council Regulation imposing restrictive measures against ISIL (Da'esh) and Al-Qaeda. This regulation amends it. Council Implementing Regulation (EU) 2025/2401: Regulation implementing additional restrictive measures against ISIL (Da'esh) and Al-Qaeda. Al-Qaeda: Terrorist organization targeted by restrictive measures. ISIL (Da'esh): Terrorist organization targeted by restrictive measures. Allied Democratic Forces: Entity added to the list of those subject to restrictive measures under Annex I to Regulation (EU) 2016/1686.
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Official Journal EN of the European Union L series 2025/2401 24.11.2025 COUNCIL IMPLEMENTING REGULATION (EU) 2025/2401 of 24 November 2025 implementing Regulation (EU) 2016/1686 imposing additional restrictive measures directed against ISIL (Da’esh) and Al-Qaeda and natural and legal persons, entities or bodies associated with them THE COUNCIL OF THE EUROPEAN UNION, Having regard to the Treaty on the Functioning of the European Union, Having regard to Council Regulation (EU) 2016/1686 of 20 September 2016 imposing additional restrictive measures directed against ISIL (Da’esh) and Al-Qaeda and natural and legal persons, entities or bodies associated with them(1), and in particular Article 4(1) 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 Regulation (EU) 2016/1686. (2) In view of the continued threat posed by ISIL (Da’esh) and Al-Qaeda and persons, entities and bodies associated with them, one entity should be added to the list of natural and legal persons, entities and bodies set out in Annex I to Regulation (EU) 2016/1686. (3) Regulation (EU) 2016/1686 should therefore be amended accordingly, HAS ADOPTED THIS REGULATION: Article 1 Annex I to Regulation (EU) 2016/1686 is amended in accordance with the Annex to this Regulation. Article 2 This Regulation shall enter into force on the date 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, 24 November 2025 For the Council The President L. LØKKE RASMUSSEN (1) OJ L 255, 21.9.2016, p. 1, ELI: http://data.europa.eu/eli/reg/2016/1686/oj. ELI: http://data.europa.eu/eli/reg_impl/2025/2401/oj 1/2EN OJ L, 24.11.2025 ANNEX In Annex I to Regulation (EU) 2016/1686, the following entry is added under the heading ‘B. Legal persons, entities and bodies referred to in Article 3’: ‘8. Allied Democratic Forces.’. 2/2 ELI: http://data.europa.eu/eli/reg_impl/2025/2401/oj

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