Written statement on Operation of the UK’s Counter-Terrorist Asset Freezing Regime: 1 July 2017 to 30 September 2017 and 1 October 2017 to 31 December 2017

This report also covers the UK’s implementation of the UN’s ISIL (Da’esh) and Al-Qaida asset freezing regime (ISIL-AQ), and the operation of the EU’s asset freezing regime under EU Regulation (EC) 2580/2001 concerning external terrorist threats to the EU. (also referred to as the CP 931 regime).

Under the ISIL-AQ asset freezing regime, the UN has responsibility for designations and the Treasury, through its Office of Financial Sanctions implementation (OFSI), has responsibility for licensing and compliance with the regime in the UK under the ISIL (Da’esh) and Al-Qaida (Asset-Freezing) Regulations 2011.

Under EU Regulation 2580/2001, the EU has responsibility for designations and OFSI has responsibility for licensing and compliance with the regime in the UK under Part 1 of TAFA 2010.

A new EU asset freezing regime under EU Regulation (2016/1686) was implemented on 22 September 2016. This permits the EU to make autonomous Al-Qaida and ISIL (Da’esh) listings. Once a designation is made under this regime it will appear in the table below.

The annexed tables set out the key asset-freezing activity in the UK during each quarter.

The Sanctions and Anti-Money Laundering Bill currently before Parliament will help ensure that UK counterterrorist sanctions powers remain a useful tool for law enforcement and intelligence agencies to consider utilising, while also meeting the UK’s international obligations.

Under the Bill, a designation could be made where there are reasonable grounds to suspect that the person or group is or has been involved in a defined terrorist activity and that designation is appropriate. This approach is in line with the UK’s current approach under UN and EU sanctions and would be balanced by procedural protections such as the ability of designated persons to challenge the Government in court.