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Following recent developments in the Middle East, the Sanctions Monitoring Board (the “SMB”) has issued a guidance note on the targeted counter-terrorism sanctions which are applicable to Malta in terms of Article 7(5)(b) of the National Interest (Enabling Powers) Act (Chapter 365 of the laws of Malta). This guidance note follows the conflict which arose in the Gaza Strip on the 7th October 2023.

This guidance note highlights the sanctions imposed by the European Union to counter terrorism and reduce the financing of terrorist groups through specific restrictive measures. These measures are being directed at specific persons and entities in terms of Regulation (EC) No 2580/2001. Through this regulation, the EU has enacted additional measures to ensure the implementation of UN Security Council Resolution 1373 (2001). Through these measures a list of designated individuals, groups and entities involved with terrorist-related activities is set up. These measures also establish the freezing of assets and financial resources and enhanced measures for police and judicial cooperation.

The SMB notes in their guidance issued on the 6th November 2023 that a number of groups, including Hamas, the Palestinian Islamic Jihad Shaqaqi and the Popular Front for the Liberation of Palestine are included as designated entities. These entities, together with other entities, are subject to an asset freeze and the prohibition from funds and economic resources being made available.

This guidance note also provides information on the provision of donations to Gaza. The SMB notes the importance of ensuring strict adherence to all restrictive measures imposed and the importance of identifying the final recipient of the funds being donated. The SMB has also suggested that due diligence measures be undertaken when dealing with persons, entities and bodies listed under national sanctions issued by other countries.

For further information on this guidance note, one may visit the following link:

This document does not purport to give legal, financial or tax advice. Should you require further information or legal assistance, please do not hesitate to contact Dr. Edmond Zammit Laferla or Dr. Zachary Galea