A Guide to Understanding the Legal Framework of UN Sanctions

The UN Security Council has the authority to take actions for the maintenance or restoration of international peace and security under  Chapter VII of the United Nations Charter.

UN sanctions are measures imposed by the United Nations Security Council (UNSC). This means that all the UN member states, whether they possess an autonomous sanctions regime or not, have to implement these resolutions.

Sanctions are imposed for some purpose, such as fighting terrorism, re-establishing democracy, hindering nuclear proliferation, and promoting human rights. Therefore, to achieve these goals, universal compliance with the UN sanctions list is essential.

In terms of promoting peace, security, and sustainable economic development, the United Nations always leads the way. To achieve these goals, the UN has dedicated itself to fighting terrorism and money laundering. They perform this task by listing countries, individuals, and entities on the UN consolidated sanctions lists.

The United Nations sanctions list then assists businesses, regulators, and compliance officers in identifying high-risk entities and preventing transactions that could break international laws or sanctions.

Legal Basis and Operational Process of UN Sanctions

The authority of the UN Security Council to impose sanctions stems from Chapter VII of the UN Charter, particularly:

• Article 39:  empowers the Council to identify the existence of a threat to peace, a breach of peace, or an act of aggression.
• Article 41: allows the imposition of non-military measures such as travel bans, arms embargoes, and asset freezes.
• Article 42:  permits the use of force if non-military measures prove inadequate.

This framework ensures that sanctions are both lawful and enforceable across all UN Member States.

Comprehensive and Targeted UN Sanctions

In the past, the UN sanction were in the form of comprehensive sanctions. The actions taken by such sanctions were wide-ranging, covering entire countries, such as full trade embargoes. The major objective behind these sanctions is to put severe economic and political pressure on a targeted regime or authority.  Such sanctions are imposed in the hope that the counterparty can change its policies or behavior due to economic or political pressure. Comprehensive sanctions mostly have negative impacts. And mostly, the people who have no role in the policies suffer more because of the economic struggle caused by the sanctions.

For instance, during the 1990s, the United Nations imposed comprehensive sanctions on Iraq (1990–2003) following its invasion of Kuwait. These included a total trade and financial embargo that severely impacted the country’s economy and civilian population. Similarly, the former Yugoslavia was subjected to sweeping UN sanctions in the early 1990s due to the violent conflicts and human rights violations during its disintegration. These cases highlighted the humanitarian consequences of such broad measures.

Recognizing the struggle of the innocent individuals who suffer because of the economic and political pressure. All the focus shifted towards targeted sanctions, also known as smart sanctions. These sanctions are imposed especially on the entities, countries, and individuals that are actually involved in some criminal activity, such as spreading terrorism or performing money laundering. Targeted sanctions include:

• Asset Freezing (Stopping individuals or entities from moving funds and economic resources)
• Travel Bans ( Preventing individuals from leaving UN member states)
• Arms embargo ( Prohibiting the sale, transfer, or supply of weapons and relevant material to any entity or individual)

This shift towards targeted sanctions highlights a stronger realization that precision and accountability are essential for effective international diplomacy.

FATF Recommendation 6 and the Global Fight Against Financial Crime

Financial Action Task Force (FATF) Recommendation 6 has reinforced the global fight against financial crime, such as terrorist financing and proliferation. Recommendation 6 of FATF is a specific guideline that emphasizes targeted financial sanctions. This means banning and freezing the assets of the entities, individuals, and countries that are actually involved in any kind of financial crime. Its main agenda is to focus on economy-wide sanctions rather than a wide-ranging one that includes the whole nation. This recommendation ensures the dire need for countries to ban travel and freeze the assets of terrorists to prevent their illegal activities.

The core obligation is to comply with relevant UN Security Council Resolutions, specifically those related to the suppression and prevention of terrorist financing, such as:

UN Security Council Resolution (UNSCR) 1267 (1999)

The primary objective of UNSCR 1267 was to target AL-Qaeda, the Taliban, and their associated individuals to disrupt their terrorist acts. It was adopted under Chapter VII of the UN Charter. This committee is accountable for:

• Handling and updating the United Nations Security Council Consolidated list of entities and individuals subject to the sanctions.
• Tracing and encouraging the implementation of the sanctions regime.
• Reviewing listing and de-listing requests.

UN Security Council Resolution (UNSCR) 1269 (1999)

UNSCR 1269 was adopted in 1999, a couple of years before the 9/11 attacks, which highlights that the international community was already facing severe challenges relevant to terrorism. Therefore, to control the scale of the threat, Resolution 1269 was introduced. The major directives were:

• Clear condemnation of terrorism
• Call for State Cooperation to Prevent and Suppress
• Measures to Prevent Financing and Preparation
• No Specific Sanctions List, but Important Groundwork

UN Security Council Resolution (UNSCR) 1373 (2001)

UNSCR 1373 resolution is a crucial international terrorism measure approved right after the disastrous 9/11 attacks in the United States. Likewise, Resolution 1267, UNSCR 1373 was adopted under the same Chapter VII of the UN Charter. This means that all 193 UN Member States are required to integrate these mandates into their national legal frameworks. The obligations within this resolution include:

• Freezing Terrorist Assets
• Prevent Terrorist Movements
• Cooperating with International Standards
• Criminalizing the Terrorist Financing
• Banning Terrorist Entries

The De-Listing Process in UN Sanctions

The UN Security Council allows for the removal of individuals, entities, or states from its sanctions list through a formal de-listing process. This occurs when the listed party no longer poses a threat or has complied with UN mandates. In July 2025, the UNSC lifted sanctions on Liberia, recognizing its post-conflict recovery and stable governance (SC/16082).

Under regimes like Resolution 1267, if the de-listing request is submitted by the listed individual or entity, it is reviewed by the UN Ombudsperson, who then submits a recommendation to the relevant Sanctions Committee. However, if the request is made by a UN member state, it is submitted directly to the Committee for review. This mechanism ensures sanctions are not indefinite and can be reversed through peaceful behavior and international cooperation.

In conclusion, UN sanctions, driven by resolutions like 1267, 1373, and 1269, and reinforced by international standards such as FATF Recommendation, represent a vital component of international efforts to maintain peace and security. Their evolution from broad, comprehensive measures to precise, targeted interventions demonstrates a commitment to effectiveness and minimizing humanitarian impact, while the universal obligation for compliance underscores their indispensable role in the global legal and security architecture.

Challenges of Compliance with UNSC Sanctions for Financial Institutions

Financial institutions face growing complexity in complying with UN Security Council (UNSC) sanctions. As noted in Deloitte’s 2024 Sanctions Compliance Survey, nearly 70% of firms struggle to maintain updated lists across jurisdictions. The burden is especially heavy for global banks, where Global Investigations Review highlights that “implementation of UN sanctions may differ,” requiring nuanced, cross-border assessments. In correspondent banking, indirect exposure and limited beneficial ownership data further complicate risk screening and increase regulatory risk.

These challenges underscore the need for strong sanctions screening frameworks and real-time list management

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