UN Sanctions De-Listing Procedures: A Guide

Overview

This article outlines the procedures for de-listing individuals and entities from UN sanctions lists, as outlined in relevant guidelines and regulations.

Submitting De-Listing Requests

To initiate the de-listing process, you must address your request to one of the following authorities:

• The co-ordinator designated by the sanctions committee
• The UN Ombudsman

When submitting your request, ensure that you provide specific information or documents as outlined in paragraph 59 of the Regulation.

SIS Decision and Notification

The State Intelligence Service (SIS) has the authority to issue a decision on removing restrictive measures based on amendments to the UNSCRs lists. Once a decision is made, it must be communicated to the relevant parties, including:

• The entity that applied the freezing measure (RE)
• Other interested parties as required by law or regulation

Limitations and Exceptions

While this guidance outlines procedures for de-listing, it does not explicitly address the obligations of non-RE entities (e.g. individuals or companies) holding targeted funds or assets in cases where a person or entity is removed from the sanctions list.

Key Takeaways

• To de-list an individual or entity, submit a request to the designated co-ordinator or UN Ombudsman
• Provide specific information or documents as outlined in paragraph 59 of the Regulation
• The SIS issues decisions on removing restrictive measures based on amendments to UNSCRs lists
• Relevant parties must be notified of any de-listing decision