top of page

EU & UK Trade & Financial Sanctions Briefing: Libya

(S,P) Libya is currently subject to sanctions. Background, lists and latest legal updates here.

SUMMARY: What sanctions are imposed

  • Arms export: It is prohibited to export equipment that might be used for internal repression to Libya. Related technical assistance, training, financial and other assistance is also prohibited.

  • Arms procurement: It is prohibited to procure arms and related material, as well as equipment that might be used for internal repression, from Libya.

  • Asset freeze and prohibition to make funds available: All assets of the listed persons and entities should be frozen. It is also prohibited to make any funds or assets directly or indirectly available to them.

  • Flights, airports: Countries deny permission to any aircraft to take off from, land in or overfly their territory if they have information that the aircraft contains prohibited items.

  • Inspections: Counties shall inspect the cargo of vessels and aircraft bound to or from Libya if they have information that the cargo contains prohibited items. Upon discovery, countries shall seize and dispose prohibited items.

  • Ports and vessels: In the absence of direction from the Government of Libya, a country that is a flag State of a designated vessel, shall direct the vessel not to load, transport, or discharge crude oil illicitly exported from Libya. Financial transactions with respect to crude oil illicitly exported from Libya aboard designated vessels are also prohibited. Councries shall deny entry into their ports of designated vessels.

  • Prohibition to satisfy claims: It is prohibited to satisfy claims made by Libyan persons, entities, bodies; or persons listed the relevant regulations in connection with any contract or transaction the performance of which has been affected by the measures imposed by the same regulation.

  • Restrictions on admission: Travel restrictions on persons listed in the Libya regulations may be imposed.

  • Restrictions on equipment used for internal repression: It is usually prohibited to export equipment that might be used for internal repression to Libya. Related technical assistance, training, financial and other assistance is also prohibited.

  • Vessels: Prior authorisation by the national competent authority of the country concerned is required for the export to Libya of goods listed in the relevant annexes of the regulations applicable (which could be used for smuggling of migrants and trafficking in human beings), as well as for related technical assistance, brokering services, financing or financial assistance.

  • Vigilance: Countries imposing sanctions may require their nationals, persons subject to their jurisdiction and firms incorporated in their territories to exercise vigilance when doing business with entities incorporated in Libya or subject to Libya's jurisdiction, with a view to preventing business that could contribute to violence and the use of force against civilians.

Why Sanctions?

This sanctions regime of countries, like the EU or the UK, gives effect to the obligations under United Nations Security Council Resolutions (UNSCRs) including UNSCR 1970 (2011) as well as additional autonomous measures the aims of which are to promote:

  • respect for human rights in Libya;

  • the peace, stability and security of Libya;

  • the successful completion of Libya’s political transition to a democratic, independent and united country; and

  • the prevention of migrant smuggling and human trafficking taking place from Libya.

EU Restrictive measures in view of the situation in Libya In view of the seriousness of the situation in Libya, on 26 February 2011 the UN Security Council adopted Resolution 1970 (2011), introducing restrictive measures in relation to persons and entities involved in serious human rights abuses against persons in Libya. The Security Council has since adopted a number of other resolutions on Libya that have extended or amended the measures.

What did the EU do? On 28 February 2011, the Council of the EU implemented the first UN Resolution and imposed additional restrictive measures in view of the seriousness of the situation in Libya. In its 17 July 2017 conclusions on Libya, the Council expressed its readiness to repeal the restrictive measures if the conditions for their application are no longer met, as well as introduce new measures against individuals who threaten the peace, security or stability of the country, impede the completion of Libya's political transition and are responsible for serious human rights abuses. Following the adoption of UN Resolution 2441 (2018) of 5 November 2018, restrictive measures explicitly apply to persons planning, directing or committing acts involving sexual and gender-based violence.

What does the EU impose?

The Libya sanctions regimes permit the designation of persons (both individuals and entities) for the purpose of imposing an asset freeze as well as various financial prohibitions if those persons are involved in serious human rights abuses or breaches of international humanitarian law in Libya (including attacks on civilians and facilities), an activity carried out on behalf of the former regime of Muammar Qadhafi and any other activity which threatens the peace, stability or security of Libya (including attacking infrastructure and misappropriating Libyan state funds).

Asset Freezes

Asset freezing activity also helps protect Libyan state funds (misappropriated during the former regime of Muammar Qadhafi) which could be used to threaten the peace, stability or political transition of Libya.

A full asset freeze is imposed on various persons. Separately a partial asset freeze is imposed on two UN-designated persons, the Libyan Investment Authority and the Libyan Africa Investment Portfolio. That partial asset freeze applies for funds and economic resources owned, held or controlled by those two designated persons located outside Libya immediately before 17 September 2011, funds transferred on or after 17 September 2011 to the designated persons to meet a prior obligation, as well as interest and other earnings that have accrued on either of the aforementioned on or after 17 September 2011.


Prohibitions are in place on persons (both individuals and entities) entering into any financial transactions relating to Libyan oil aboard an UN-designated ship. This includes the purchase, or sale, or use of credit and the taking out of transport insurance in respect of it.

UN regulations

The UN Resolution, UNSCR 1970 (2011), is available online along with other relevant UN Resolutions.

UK regulations

The Libya (Sanctions) (EU Exit) Regulations 2020

The Libya (European Union Financial Sanctions) Regulations 2016 (S.I. 2016/45) (applicable prior to 31 December 2020)

Libya (Financial Sanctions) Order 2011 (applicable prior to 31 December 2020)

More information and latest updates:

EU regulations

Council Implementing Regulation (EU) 2021/1909 of 4 November 2021 implementing Article 21(1) of Regulation (EU) 2016/44 concerning restrictive measures in view of the situation in Libya

Latest EU Updates



5 November 2021 -

19 views0 comments

Recent Posts

See All
bottom of page