Targeted Financial Sanctions

Legal Framework:


Targeted Financial Sanctions:

Freezing and prohibiting the transfer, conversion, disposition or movement of funds, directly or indirectly, for designated persons and entities.

Freezing: To prohibit the transfer, conversion, disposition or movement of funds, in application of the targeted financial sanctions, for persons and entities placed on the Sanctions List, for the duration of the validity of the designation order.

Funds: Assets or property of every kind, whether physical or nonphysical, tangible or intangible, movable or immovable, including financial assets, economic resources, such as oil and other natural resources, and all related rights of any value, however acquired, and all legal documents or instruments in any form, including digital or electronic copies, evidencing title to, or share in, such assets, and any interest, dividends or other income on or value accruing from or generated by such funds, and any other assets which potentially may be used to obtain funds, goods or services.

Sanctions List: A list established by a decision of the Public Prosecutor and maintained by the National Counter Terrorism Committee (NCTC), including the following:

  • The natural persons and entities designated on the UN Security Council List.
  • The natural persons and entities designated by a decision of the Public Prosecutor, at the proposal of the NCTC.

The UN Security Council List or the UN Security Council Consolidated List:

A list established and maintained by the appropriate United Nations body, that includes all persons and entities subject to targeted financial sanctions by a UN Security Council resolution.  It may also include individuals entities, and groups subject to targeted financial sanctions for financing the proliferation of weapons of mass destruction, pursuant to the UN Security Council resolutions, and all their relevant identification information.

The following shall be designated on the Sanctions List:

  • Any person or entity designated by the Public Prosecutor by virtue of a Security Council or Sanctions Committee resolution pursuant to Chapter VII of the Charter of the United Nations.
  • Any person or entity designated by virtue of a decision by the Public Prosecutor, upon the proposal of the NCTC, without initiating a criminal proceeding, in any of the following cases:
  1. If there are reasonable grounds or reasonable basis to believe that the person or entity will commit, finance, threatens, plans, attempts, promote, or incite to commit terrorist acts or any related acts, or facilitates or participates in such acts, or trains or facilitates the travel of individuals to another State for the purpose of committing, devising, preparing for, or participating in terrorist acts. The designation shall include any entity owned or controlled, directly or indirectly, by a designated person or entity pursuant to this item, or any person or entity acting on their behalf, or at their direction.
  2. If the person or entity carries out an armed or unarmed terrorist act against the State or its interests abroad.
  3. If the person or entity has publicly recognized, adopted, threatened, incited or publicly promoted a terrorist act.

The NCTC shall publish the designations on its website immediately upon the issuance of the designation orders by the Public Prosecutor.

Obligations of supervised entities in terms of implementation of targeted financial sanctions:

  • Auditors, dealers in precious metals or stones and trust and company service providers develop appropriate systems to verify their compliance with the implementation of targeted financial sanctions.
  • To review and clarify the obligations of auditors, dealers in precious metals or stones and trust and company service providers in terms of the requirements for implementation of targeted financial sanctions stated in Law No. (27) of 2019 on Combating Terrorism, Decision No. (1) of 2020 of the Public Prosecutor Regulating the Implementation Mechanisms of the Targeted Financial Sanctions related to Combatting the Financing of Terrorism and the Financing of the Proliferation of Weapons of Mass Destruction pursuant to the Law on Combatting Money Laundering and Terrorism Financing, the Law on Combatting Terrorism, and the UN Security Council Resolutions, Decision No. (59) of 2020 Promulgating Guidelines to the Effective Implementation of the Targeted Financial Sanctions Regime in the State of Qatar and the AML/CFT Compliance Rules for Auditors, Dealers in Precious Metals or Precious Stones and Trust and Company Service Providers, please refer to the following: