Financial Sanctions Imposed On Libya

The United Nations, the Council of the European Union, the United States, the United Kingdom, and other countries have imposed targeted financial sanctions on Libya. The sanctions primarily target Muammar Qadhafi, his family, their assets, and in the case of US sanctions, Libyan government-owned or controlled entities. Many other countries are also reportedly considering the imposition of sanctions against Libya.

On February 26, 2011, the United Nations Security Council adopted Resolution 1970 (2011) in response to the Qadhafi regime's actions against political protestors and the civilian population in Libya. UNSCR 1970 requires blocking assets of Muammar Qadhafi, specified members of his family, persons acting on behalf or at the direction of those persons, or entities owned or controlled by Muammar Qadhafi or his family.

On February 28, 2011, the Council of the European Union announced that an arms embargo and targeted sanctions were being imposed against Libya. In accordance with UNSCR 1970, the sanctions would consist of a visa ban and a freeze of assets against Muammar Qadhafi, his close family members, and other persons responsible for the internal crackdown. It also appeared that the Council intended to adopt an asset freeze on other individuals beyond those named in UNSCR 1970.

A number of nations moved rapidly over the weekend to implement the Security Council Resolution. The United Kingdom, for example, enacted Libya (Financial Sanctions) Order 2011 on February 26, 2011, which gives effect to UNSCR 1970. Canada and Australia have also imposed sanctions.

One day prior to the UNSCR 1970, President Obama issued an Executive Order blocking the assets of (and prohibiting business by US persons with) the same persons designated in UNSCR 1970, known as Specially Designated Nationals and Blocked Persons (SDNs), and also imposing broader sanctions against the Government of Libya; its agencies, instrumentalities, and controlled entities; and the Central Bank of Libya. Effective February 25, 2011, any property or interests in property of the Government of Libya, its "controlled" entities, or the Central Bank of Libya now must be blocked, and US persons are prohibited from conducting transactions and dealings with those persons and entities, e.g., transfers; payments; performing contracts; exports of goods, services, or technology; or withdrawals. Any property so blocked must be notified to OFAC by written report within 10 days. (The...