Category: Sanctions Programs

UNSCR 1267

Also known as: UNSCR 1267, United Nations Security Council Resolution 1267, S/RES/1267 (1999), Resolution 1267

Simply put

UNSCR 1267 is a resolution adopted by the United Nations Security Council on 15 October 1999 that created a sanctions regime originally targeting the Taliban and associated individuals and entities. It introduced restrictive measures such as a financial embargo and a limited air embargo, and it established a dedicated Security Council Committee to oversee the regime. Over time, the regime evolved to focus on individuals and entities linked to ISIL (Da'esh) and Al-Qaida.

Formal definition

United Nations Security Council Resolution 1267 (1999), adopted unanimously on 15 October 1999, established a thematic counter-terrorism sanctions regime that initially imposed a limited air embargo and a financial embargo on the Taliban and created the associated Security Council Committee (the '1267 Committee') to administer the regime and maintain the related sanctions list. The regime designated Osama bin Laden and associates and was subsequently developed through successor resolutions, including resolutions 1989 (2011) and 2253 (2015), under which the Committee became the Security Council Committee concerning ISIL (Da'esh), Al-Qaida and associated individuals, groups, undertakings and entities. As a UN Security Council instrument, the 1267 regime provides the international framework for asset-freezing and related restrictive measures that member states are expected to implement domestically; the precise scope, listing criteria, and current designations are managed by the Committee, and practitioners should confirm the applicable consolidated list and implementing measures in their own jurisdiction.

Why it matters

UNSCR 1267 is one of the foundational instruments in the international counter-terrorism sanctions architecture. Adopted unanimously on 15 October 1999, it created a thematic sanctions regime and a dedicated Security Council Committee (commonly called the '1267 Committee') to administer restrictive measures and maintain the associated sanctions list. Because it originates from the UN Security Council, the regime provides an international framework that member states are expected to implement through their own domestic legal and regulatory measures. For compliance professionals, this means the 1267 designations sit upstream of many national and regional sanctions lists, and understanding the regime helps explain why certain names appear across multiple jurisdictions' consolidated lists.

The regime's evolution matters operationally. It began by targeting the Taliban and designated Osama bin Laden and associates, and through successor resolutions including 1989 (2011) and 2253 (2015) it was reoriented toward individuals, groups, undertakings, and entities associated with ISIL (Da'esh) and Al-Qaida. Designations under the regime are actively maintained: for example, the Committee periodically amends existing entries, as reflected in national notices such as one issued by the Office of the Attorney General of the Bahamas noting that the Committee had amended seven entries on the ISIL (Da'esh) and Al-Qaida list. This underscores that the sanctions list is not static, and that firms must continuously refresh their screening data against current designations.

Because designations can carry asset-freezing and related restrictive-measure consequences once implemented domestically, obliged entities that fail to screen against and act upon the applicable list may face regulatory and legal exposure. At the same time, a name match is a screening result that requires investigation and confirmation against the applicable implementing measures in the relevant jurisdiction; it is not, by itself, a finding of wrongdoing. Practitioners should confirm the current consolidated list and the precise implementing rules that apply to them rather than relying on the UN instrument in isolation.

Who it's relevant to

Sanctions compliance officers

Those responsible for sanctions programs must ensure their screening data reflects the current designations flowing from the 1267 regime as implemented in their jurisdiction, and that processes exist to capture amendments to entries as the Committee updates the list. Because the regime is implemented domestically rather than applied directly, they should map how the applicable consolidated list and implementing measures translate into their screening obligations.

Financial intelligence and investigations analysts

Analysts reviewing potential matches against 1267-derived designations need to understand that a name match is a screening result requiring investigation and confirmation, not a determination of wrongdoing. Familiarity with the regime's focus on ISIL (Da'esh) and Al-Qaida associated persons and entities helps contextualize alerts and prioritize verification against the current list.

Legal and regulatory teams at obliged entities

Legal and risk professionals should confirm the precise scope of asset-freezing and related restrictive measures as enacted in their jurisdiction, since the 1267 resolution is a UN instrument that member states implement through domestic law. They play a key role in interpreting how implementing measures apply to specific situations and in ensuring the firm acts consistently with the applicable rules.

Firms operating across multiple jurisdictions

Because 1267 designations are expected to be implemented by member states individually, cross-border firms may encounter divergence in the precise scope, timing, and mechanics of implementation. Such firms should verify the applicable consolidated list and implementing measures in each relevant jurisdiction rather than assuming a single uniform standard applies everywhere.

Inside UNSCR 1267

UN Security Council Resolution

UNSCR 1267 is a resolution adopted by the UN Security Council, originally in 1999, that established a sanctions framework initially targeting the Taliban and subsequently expanded through successor resolutions to address Al-Qaida and associated individuals and entities. As a Security Council measure adopted under Chapter VII of the UN Charter, it creates binding obligations on UN member states, which must then implement it through their own domestic legal instruments.

The 1267 Sanctions Committee

The resolution created a subsidiary body of the Security Council, commonly referred to as the 1267 Committee (now associated with the ISIL (Da'esh) and Al-Qaida Sanctions Committee following later resolutions), responsible for overseeing the sanctions regime, maintaining the associated list, and considering listing and delisting matters.

Consolidated sanctions list

The regime is associated with a list of designated individuals and entities to whom the measures apply. Obliged entities in many jurisdictions screen customers and transactions against sanctions lists derived from or incorporating these designations, though the precise list applied operationally depends on how the relevant jurisdiction has implemented and consolidated UN designations.

Targeted financial sanctions measures

The core measures typically include asset freezes, prohibitions on making funds or economic resources available to designated persons, and travel bans and arms embargoes as applied to those designated. The scope and exact wording of these obligations depend on the implementing law in each jurisdiction.

Relationship to FATF standards

FATF Recommendation 6 addresses targeted financial sanctions related to terrorism and terrorist financing and refers to the implementation of relevant UN Security Council resolutions, including the 1267 regime. FATF Recommendations are standards rather than binding law, and they set expectations for how countries should give effect to these UN obligations.

Domestic implementation layer

UNSCR 1267 does not operate directly on private-sector obliged entities; it takes legal effect through implementing measures such as EU regulations, the relevant UK sanctions regime, US authorities administered by OFAC, and equivalent national instruments elsewhere. Practitioners are bound by the applicable domestic instrument rather than the resolution text itself.

Common questions

Answers to the questions practitioners most commonly ask about UNSCR 1267.

Is UNSCR 1267 the same as a national sanctions list, so that complying with my domestic regime automatically means I comply with 1267?

Not exactly. UNSCR 1267 established a UN Security Council sanctions framework, and the associated Consolidated List is maintained at the UN level. However, UN sanctions are not directly binding on private entities until they are implemented into applicable domestic or regional law. Depending on your jurisdiction, this may occur through national legislation, regulations, or regional instruments, which can differ in timing, scope, and the precise designations they incorporate. Obliged entities generally need to screen against the sanctions lists applicable to them under their own regime, which may include but is not limited to designations originating from the 1267 framework. You should confirm which lists apply against the specific regulations governing your operations.

Does a positive screening match against the 1267 Consolidated List prove that a customer is a terrorist or has committed a crime?

No. A screening match is an operational indicator that a name or other identifier potentially corresponds to a designated party; it is not a finding of criminal guilt. Designation under the 1267 framework is an administrative measure imposed by the UN Security Council and implemented through applicable law, not a criminal conviction. Matches also frequently turn out to be false positives requiring further review to confirm or discount. A confirmed true match typically triggers compliance obligations such as freezing and reporting under the applicable regime, but it does not itself establish that the customer has engaged in wrongdoing in a criminal-law sense.

Which sanctions list should an obliged entity screen against to address 1267 obligations?

In practice, entities should screen against the sanctions lists that apply to them under their own jurisdiction's implementing measures, which generally reflect the UN Consolidated List but may be supplemented or given legal effect through national or regional instruments. Many programmes screen against the relevant implementing list rather than the raw UN list itself. The precise list, its update cadence, and how designations are incorporated should be confirmed against the applicable regulations governing the entity.

What should an obliged entity generally do when it identifies a confirmed match to a designated party?

Where a match is confirmed under the applicable regime, entities are typically required to apply asset-freezing measures, refrain from making funds or economic resources available to the designated party, and report the match to the relevant competent authority in accordance with local law. The exact steps, timeframes, and reporting channels vary by jurisdiction and should be confirmed against the applicable sanctions regulations. Actions taken in response to a suspected match, before confirmation, should follow the entity's internal escalation and review procedures.

How does sanctions screening under the 1267 framework differ from PEP screening?

Sanctions screening seeks to identify parties subject to legally applicable restrictive measures, such as those designated under the 1267 framework as implemented in the relevant jurisdiction, which generally carry mandatory consequences like freezing and prohibitions on dealing. PEP screening, by contrast, identifies politically exposed persons for the purpose of applying enhanced due diligence and risk management measures; PEP status is not a sanction and does not by itself trigger freezing or prohibition. The two are distinct control objectives and should not be conflated, even where the same screening tools process both.

How should an entity handle updates to designations under the 1267 framework?

Because designations can be added, amended, or removed, entities generally need processes to incorporate changes to the applicable implementing list on an ongoing basis and to re-screen existing customers and relevant transactions accordingly. The appropriate frequency and method of re-screening depend on the entity's risk profile and the requirements of its jurisdiction. The timing of when a UN-level change becomes legally effective for a given entity depends on how and when it is implemented into applicable law, which should be confirmed against the relevant regime.

Common misconceptions

UNSCR 1267 applies directly to banks and other obliged entities as a self-executing global rule.

The resolution binds UN member states, which must implement it through domestic legal instruments. Obliged entities are subject to those national or regional implementing measures, and the exact obligations, scope, and enforcement can vary by jurisdiction. The applicable domestic instrument should always be confirmed.

UNSCR 1267 sanctions and anti-money laundering obligations are the same thing.

The 1267 regime concerns targeted financial sanctions linked to terrorism and terrorist financing, which is conceptually distinct from money laundering. Sanctions screening against 1267-derived designations serves a different purpose from AML customer due diligence and transaction monitoring, even though a single institution may operate both types of control.

A screening match against a 1267-related designation proves that the customer is a terrorist or has committed a crime.

A screening alert or potential match is an operational indicator that requires investigation and confirmation of a true match. Designation itself is an administrative sanctions measure and does not, by itself, establish criminal wrongdoing by the customer, nor does a match constitute proof of an offence.

Best practices

Screen against the sanctions list as implemented in your applicable jurisdiction rather than assuming a single global 1267 list applies, and confirm which consolidated or domestic list governs your obligations.

Treat potential matches as alerts requiring investigation and true-match confirmation, and document the disposition rather than acting on unverified name similarities.

Map your sanctions controls to the correct legal source, distinguishing UN-level designations from the implementing instruments (such as EU, UK, or OFAC-administered authorities) that actually bind your institution.

Keep screening data current by monitoring updates to designations and delistings issued through the relevant sanctions committee and reflected in the lists you apply.

Maintain sanctions screening as a control distinct from AML customer due diligence and transaction monitoring, recognising that terrorist-financing sanctions and money laundering are separate concepts requiring tailored measures.

Verify exact obligations, prohibited conduct, and any licensing or exemption provisions against the applicable implementing regulation, and seek legal guidance where scope or asset-freeze application is uncertain.