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De-Listing Procedures for Sanctions Lists Maintained by the UN and Implemented by European Countries

The process of de-listing from sanctions lists maintained by the United Nations (UN) and implemented by European countries involves several key procedures. These procedures aim to ensure that individuals or entities who no longer meet the criteria for designation are removed from these lists in a timely and transparent manner.

Procedures for De-Listing

There are publicly known procedures for submitting de-listing requests to the UN sanctions committees (1267/1989 and 1988) through the Ministry of Foreign Affairs, European Integration, and International Cooperation (MFAEI) or the coordinator designated by the sanctions committees. Additionally, the Schengen Information System (SIS) can issue a decision on removal of restrictive measures based on amendments to UN Security Council Resolution (UNSCR) lists.

Key Steps for De-Listing

  • Request to submit de-listing requests through the MFAEI or the designated coordinator
  • SIS decision on removal of restrictive measures based on UNSCR list amendments

Procedures for Reviewing Designation Decisions

There are specific legal provisions in place that allow for review of designation decisions upon request. These provisions facilitate revisions of designations and listing exclusions by the UN sanctions committee.

Key Steps for Reviewing Designation Decisions

  • Specific legal provisions for review of designation decisions
  • UNSCR committee revisions of designations and listing exclusions

Procedures for Informing Designated Persons and Entities

The Regulation provides procedures for informing designated persons and entities of the availability of the United Nations Office of the Ombudsperson. This office is established under UNSCRs 1904, 1989, and 2083.

Key Steps for Informing Designated Persons and Entities

  • Procedures for informing designated persons and entities of the availability of the Ombudsperson
  • Availability of the United Nations Office of the Ombudsperson

Communication of De-Listing Decisions

Decisions on applications or non-applications of restrictive measures shall be communicated to the relevant European authority that applied the respective measure. The decision on delisting shall also be published on the SIS’s official website and specific notices shall be sent to relevant authorities.

Key Steps for Communication of De-Listing Decisions

  • Decision communication to the relevant European authority
  • Publication and notice requirements

Identification Errors

Any person may notify the authority about any identification errors regarding listed individuals. The authority shall take a decision and ancillary action within 15 working days, as stipulated in Article 18(5) and (6) of Law 25/2016.

These procedures aim to ensure that persons or entities who no longer meet the criteria for designation are de-listed from sanctions lists in a timely and transparent manner.