Information as of: 20th December 2019

Latest Updates
Financial/Other Sanctions
UN S/Res/1970 (2011), updated September 2011 (S/Res/2009), amended by S/Res/2016 (October 2011). S/Res/2146 (19 Mar 2014). S/RES/2441 (2018), S/Res/2473
US EO 13566 (2011), EO13726 and national emergency extended until 25 February 2020.
EU/UK 2011/137/CFSP, amended by (CFSP) 2015/1333, amended by (CFSP) 2018/713). Reg (EU) 2016/44 amended by Reg (EU) 2017/1325.CFSP 2017/1427.
Arms Embargo
UN S/Res/1970, updated Sep 2011 (S/Res/2009), amended by S/Res/2016 (Oct 2011) and by S/Res/2040 (Mar 2012) and by S/Res/2095 (Mar 2013). S/Res/2278
US EO 13566 (2011)
EU/UK 2011/137/CFSP amended by 2013/182/CFSP (2013). Regulations (EU) 204/2011 amended by 2015/1323 (Aug 2015)
Further Details
UN S/Res/2009 (Sep 2011) amended arms embargo to allow trade with UN personnel & interim government, extended by S/Res/2016, S/Res/2040 (Mar 2012) removes some arms restrictions from S/Res/1973, S/Res/2095 (Mar 2013) removes further arms restrictions. S/Res/2009 removed assets restrictions on a number of entities including Libyan National Oil Corporation (LNOC), updated by S/Res/2016 (removing certain restrictions on Zueitina Oil Company, Central Bank of Libya, Libyan Foreign Arab Bank, Libyan Investment Authority & Libyan Africa Investment Portfolio). Asset freeze & travel bans remain in place against certain members of Qadhafi family & political allies. S/Res/2016 removed flight ban on Libyan aircraft & no fly zone over Libya (imposed by S/Res/1973). S/Res/2146 (19 Mar 2014) prohibits financial transactions for vessels designated by the committee in respect of illicit export of Libyan crude oil. S/Res/2441 (2018) renews measures until 15 Feb 2020 and extends sanctions to vessels loading, transporting, or discharging petroleum. Sanctions relating to the illicit export of crude oil have been extended until 31 Jul 2017 (S/Res/2278 (Mar 2016)). It is unclear whether financial transactions include (re)insurance. UN S/Res/2174 (2014), effective 27 Aug 2014, reinstates requirement to obtain advanced approval from UN Committee for arms and related material. S/Res/2240 (2015) wef: 9 Oct 2015 authorises Member States for one year to inspect, seize and dispose of vessels suspected of being used for migrant smuggling or human trafficking off the coast of Libya. S/Res/2292 (2016) authorises Member States to inspect vessels believed to be carrying arms on the high seas off the coast of Libya, bound to or from Libya. Extended by S/Res/2357 (2017) and later byS/Res/2420 (2018) for a period of 12 months from 11 June 2018. All restrictive measures reaffirmed wef 10 June 2019 S/Res/2473 (2019) for another year.
US Limited sanctions related to the satisfaction of claims for contracts & transactions affected by previous sanctions. New sanctions enacted (Feb 2011) included Libyan state entities including those listed by EU, a number of Libyan airlines, banks & LNOC. Sep 2011 - OFAC issued general license authorising all transactions involving the Govt of Libya, its agencies, instrumentalities & controlled entities, & Central Bank of Libya, (excepting certain property previously blocked, which remains frozen, & transactions involving certain persons who continue to be named as specially designated nationals) - list periodically updated. Measures under EO13566 extended until 25 Feb 2020.
EU/UK Oct 2004 EU repealed arms, flight bans & trade sanctions (CP 2004/698). Council Decision 2011/137/CFSP (Feb 2011) reinserted arms embargo, assets freeze & travel bans against individuals & entities. Updated by (CFSP) 2015/1333, renewed by (CFSP) 2017/1776 and amended by (CFSP) 2018/713. Reg 204/2011 has been amended by Reg 2015/1323 which made changes to the information held on 20 individuals and 16 entities and allows competent authorities to authorise the release of frozen funds or economic resources. Reg 233/2011 in Mar 2011 amended list of designated entities (including the Central Bank of Libya, the Libyan Investment Authority & the Libyan Arab Foreign Bank), amended in Jun 2011 to include 6 major Libyan ports. Reg 1360/2011 (Dec 2011) removed Central Bank of Libya & the Libyan Arab Foreign Bank from the list of designated entities. Flight ban in Libyan airspace and on Libyan aircraft in EU airspace repealed Sep and Nov 2011 (2011/625/CFSP, 2011/729/CFSP). Loosening of UN restrictions (S/Res/2009) applied in UK & EU - Reg. 941/2011. Reg 872/2011 removed or modified restrictions applying to banks, ports airlines as noted above. Council Decision 2011/137/CFSP (22 Jan 2013) allows release of frozen funds under certain circumstances. EU and UK maintain lists of entities subject to financial sanctions. 2013/182/CFSP (2013) removes some arms restrictions in line with UN S/Res/2095. 20 Oct 2014 Council Reg 1102/2014 implementing UN S/Res/2174(2014). Council Reg 2015/374 extends listing criteria to those engaged in or provide support for acts that threaten the peace, stability or security of Libya. WEF 18 Jan 2016 all previous regulations and decisions repealed by and consolidated in Council Regulation (EU) 2016/44 and 'Libya General Licence 1" revoked with immediate effect as of 3 Mar 2016 - any acts that would be prohibited by the Libya (Financial Sanctions) Order 2011 or Reg (EU) 2016/44 must be authorised under a new licence. Reg (EU) 2017/1325 amends Reg (EU) 2016/44 to prohibit items in relation to human trafficking. CFSP 2017/1427 implements UN measures regarding vessels involved with crude oil and petroleum. Various SDN designations updated periodically.
This information has been collated by the International Underwriting Association of London and is intended as a guide only. The IUA does not accept any liability for the accuracy of this information.
This publication is intended to convey only general information about sanctions legislation and associated insurance coverage. It is not, and is not intended to be, a complete statement of the law relating to this area. It should not be relied on or be used as a substitute for legal advice in relation to any particular set of circumstances. Accordingly, IUA does not accept any liability for any loss which may arise from reliance on this information.