EU CNCL Hamas, PIJ Sanctions Regime


On Jan. 19, EU CNCL established new dedicated sanctions framework.


  • EU CNCL established a new dedicated sanctions framework and listed six individuals.
  • Follows EU CNCL Jan. 2024 listed individual in response to attacks in Israel, #128410.
  • Overview
  • EU CNCL established a dedicated framework of restrictive measures that will allow the European Union to hold accountable any individual or entity who supports, facilitates or enables violent actions by Hamas and the Palestinian Islamic Jihad (PIJ).
  • Decision was taken in view of the gravity of the recent attacks against Israel and the need to fight against violent actions that threaten peace and international security, and aims at preventing such violent actions by Hamas and PIJ in the future.
  • The new regime complements restrictive measures previously adopted against Hamas and the PIJ under Common Position 2001/931/CFSP (the EU terrorist list).
  • EU may target those who support, materially or financially, Hamas or the PIJ; as well as those who participate in planning, preparation, enabling of their violent actions.
  • Persons, groups, entities, bodies could also be listed for activities such as: supplying, selling, or transferring arms and related materiel to the two terrorist organizations.
  • Supporting actions which undermine/threaten stability/security of Israel in conjunction with Hamas and PIJ; being involved in serious violations of international humanitarian law or human rights law; inciting/publicly provoking violent actions of the organizations.
  • In addition, for the first time, the EU will also be able to target persons or entities providing support to those facilitating or enabling violent action by Hamas and the PIJ;
  • In other words, the sponsors of those who sponsor the two terrorist organizations.
  • Individuals Listed
  • EU CNCL also decided to list 6 individuals of different nationalities responsible for providing financial support to Hamas: Sudan-based financier Abdelbasit Hamza Elhassan Mohamed Khair; owner of 'Shuman for Currency Exchange SARL' Nabil Chouman.
  • The former's son Khaled Chouman; senior Hamas financier Rida Ali Khamis; senior Hamas operative Musa Dudin; and Algeria-based financier Aiman Ahmad Al Duwaik.
  • Those listed under sanctions regime are subject to an asset freeze: provision of funds or economic resources, directly or indirectly, to them or for their benefit is prohibited.
  • Additionally, a travel ban to the EU applies to the natural persons listed.
  • Official Journal
  • Dec (CFSP) 2024/385 of Jan. 19, 2024 establishing restrictive measures against those who support, facilitate or enable violent actions by Hamas and Palestinian Islamic Jihad.
  • Reg 2024/386 of Jan. 19, 2024 establishing restrictive measures against those who support, facilitate or enable violent actions by Hamas and the Palestinian Islamic Jihad.
  • Effectiveness
  • The new sanctions framework shall apply until Jan. 19, 2025, under constant review and renewed or amended if the Council deems its objectives have not been met.
  • Feb. 2024 Corrigenda
  • On Feb. 8, 2024, EU CNCL issued corrigenda to Dec (CFSP) 2024/385, Reg 2024/386.
  • In the decision, on page 9, in the Annex, entry number 4, in the column Identifying information, for: DOB: 2.9.1967 read: DOB: 20.9.1967.
  • In the regulation, on page 11, in Annex I, entry number 4, in the column Identifying information, for: DOB: 2.9.1967 read: DOB: 20.9.1967.
  • Feb. 13, 2024 Candidate Countries Alignment
  • On Feb. 13, 2024, EU CNCL announced candidate countries, North Macedonia, Montenegro, Serbia, Albania, Ukraine, Republic of Moldova, Bosnia and Herzegovina and Georgia, as well as Liechtenstein, align themselves with Dec (CFSP) 2024/385.
  • Candidate countries will ensure their national policies conform to the council decision.

Regulators EU CNCL
Entity Types B/D; Bank; BS; Ins; Inv Co; MSB
Reference PR, 2/13/2024; OJ L, 2/8/2024; PR, List, OJ L, Dec (CFSP) 2024/385, Reg 2024/386, 1/19/2024; Citation: Dec (CFSP) 2024/385; Reg 2024/386;
Functions AML; Anti-Bribery; Compliance; Financial; Human Rights; Legal; Operations; Sanctions
Countries European Union; Israel; Cross-Border
Category
State
Products Banking; Clearing; Deposits; Fund Mgt; Insurance; Loan
Regions EMEA
Rule Type Final
Rule Date 1/19/2024
Effective Date 1/19/2025
Rule Id 198458
Linked to Rule :128410
Reg. Last Update 2/13/2024
Report Section AML & Enforcement

Last substantive update on 02/15/2024