By Vittorio Maresca di Serracapriola and Natasha Hall
Contents
The Origins of 1267
Al-Qaeda’s bombings of the United States (US) embassies in Dar es Salaam and Nairobi in 1998 triggered the creation of the UN’s first modern counterterrorism sanctions regime. In 1999, the UN Security Council adopted Resolution 1267, imposing targeted sanctions on the Taliban for sheltering Osama bin Laden and refusing to hand him over. The resolution required states to freeze Taliban-linked assets and restrict their travel, with the explicit aim of pressuring the Afghan authorities to expel al-Qaeda and end their provision of “safe haven.”
To manage the new system, the Council established the 1267 Sanctions Committee—made up of all Security Council members—to compile and update a list of individuals and entities connected to the Taliban. After the 2000 bombing in Yemen of the USS Cole, a guided missile destroyer of the US Navy, the Security Council widened the regime’s scope to anyone “associated with” bin Laden or al-Qaeda, reflecting growing concern about the group’s global reach.
The 9/11 attacks accelerated the transformation of the 1267 framework and catalyzed the broader “global war on terror.” States adopted expansive emergency powers, lowered evidentiary thresholds for security action, and increasingly tolerated human-rights-constraining counterterrorism practices. At the UN, the Security Council issued a series of binding resolutions obliging member states to criminalize terrorism and terrorist financing, fundamentally reshaping domestic legal orders.
In this environment, the 1267 regime shifted from a sanctions tool geographically limited to Afghanistan into an open-ended counterterrorism instrument. Listings could now apply to individuals anywhere in the world and could last indefinitely. Within a few years, the Security Council began targeting individual terrorism suspects on the basis of classified material that merely suggested a possible “association” with al-Qaeda.
In that climate of greater seriousness toward counterterrorism, the international community—led by the US—deemed it necessary to create a group of independent experts to support the 1267 Committee, and in 2004 the Monitoring Team (MT) was established to support the Committee’s member states. The MT began producing case files, liaising with member states and regional bodies, assessing threats, and providing the Committee with independent analysis.
In 2011, recognizing the political need to accommodate the Taliban in future peace efforts, the Council split the sanctions architecture into two tracks through Resolution 1988, focused on Taliban members as threats to Afghan stability, and Resolution 1989, targeting al-Qaeda globally. In 2015, the regime was expanded again to include the Islamic State in Iraq and the Levant (ISIL).
The 1267 Committee stresses that individuals and entities may be sanctioned on the basis of states’ assessments of potential future threats, rather than solely for proven acts. Listing is designed to be preemptive: measures are imposed before a person or entity has carried out an attack, based on intelligence or risk assessments. This reflects a broader shift in global counterterrorism toward early action based on incomplete information, under the premise that waiting for threats to fully materialize would be too late. Today, the ISIL/al-Qaeda list remains the UN’s central preemptive security mechanism.
Why Hay’at Tahrir al-Sham Remains on the 1267 Sanctions List
In 2014, the Security Council added Jabhat al-Nusrah—Hay’at Tahrir al-Sham’s (HTS) precursor—to the 1267 list after the group pledged allegiance to al-Qaeda. Although the precise origin of the request is not public, some diplomats have suggested that the Syrian government, then led by Bashar al-Assad, pushed for the listing. The official rationale was that al-Nusrah was “associated with” al-Qaeda through its financing, planning, and perpetration of terrorist acts, as well as through its recruitment and logistical support for al-Qaeda and al-Qaeda in Iraq. The group’s leader, Ahmad al-Sharaa (Abu Mohammad al-Jawlani), publicly affirmed allegiance to Ayman al-Zawahiri, a former al-Qaeda leader, in April 2013.
Although al-Nusrah formally broke ties with al-Qaeda in 2016 and merged with other armed factions to establish HTS, the Council concluded that HTS was effectively an alias and extended sanctions to the new formation in 2017. HTS remains listed today, even though Sharaa announced the group’s dissolution after assuming power in Damascus.
Sharaa and Anas Khattab, the Ministry of Interior, were both under UN sanctions until 6 November 2025, when the Council voted to delist them. Fourteen members supported the resolution; China abstained. China’s Ambassador, Fu Cong, argued that the text failed to address Beijing’s broader concerns about Syria’s counterterrorism posture.
On 9 October 2025, the US reportedly circulated a draft resolution that would ease long-standing sanctions on Syrian officials and restart international engagement with the Syrian government. The draft proposed delisting Sharaa, Khattab, and HTS from the UN sanctions list.
It also sought to allow the transfer of financial assets and economic resources to Syria’s transitional government, even when listed individuals served within it, so as to deter banks from imposing excessive restrictions on their interactions with the state.
The resolution included a targeted exemption to the arms embargo to enable the International Atomic Energy Agency, the Organisation for the Prohibition of Chemical Weapons, and de-mining organizations to operate in Syria without breaching sanctions on dual-use goods.
Negotiations dragged on for months. China raised concerns that the Council was moving too quickly without securing concrete counterterrorism achievements from Sharaa. Beijing remains concerned about the Eastern Turkistan Islamic Movement in Syria, who it views as a direct national-security threat because it believes the group trains militants who could later support separatist violence in Xinjiang or target Chinese interests abroad. The group is composed of Uyghur fighters from China and Central Asia who fought alongside HTS against Assad. Many Uyghurs maintain close ties to Syria’s new leadership and have been integrated into the Syrian army despite remaining under UN sanctions.
In early November, under White House pressure to secure the delisting before Sharaa’s state visit, US diplomats narrowed the proposal to a minimalist resolution focusing solely on removing Sharaa and Khattab from the sanctions list. Beijing abstained, saying the revised text still did not resolve its concerns. Russia’s UN Ambassador Vassily Nebenzia said Moscow backed the succinct resolution because it reflects the interests and aspirations of the Syrian people.
The Sector-Wide Effects of HTS’s UN Listing
Experts often note that targeted sanctions have gradually taken on the characteristics of broader sectoral measures, a process some describe as the “comprehensivization” of sanctions. What is discussed less is how the addition of even a few individuals or entities to sanctions lists can trigger similar systemic effects. In practice, targeted sanctions can sometimes operate like sectoral ones, especially when those individuals are part of a government or de facto government body.
The UN’s continued sanctions on HTS, combined with remaining US sanctions on Syria, still complicate the country’s chances of recovering from more than a decade of war. Keeping HTS on the UN list can blunt—or in certain cases, entirely negate—the practical benefits of easing sector-wide restrictions.
This dynamic is particularly salient in Syria’s post-Assad transition. The formal relaxation of sectoral restrictions by the US, EU, and UK in the banking, oil, or reconstruction sectors has produced limited results. Several factors drive this gap: lingering market caution, security concerns, and the possibility that the UN’s ongoing designation of HTS sustains a high-risk compliance environment affecting networks connected to or perceived as aligned with the group. Even when major state-linked financial institutions receive additional latitude, their proximity to current authorities—and therefore, indirectly, to HTS—continues to deter efforts to reintegrate Syria into the global economy.
The reintegration of the Commercial Bank of Syria (CBoS) into the global financial system remains uncertain. Although the US has suspended sanctions on CBoS, international banks may remain cautious given the institution’s association with state authorities and by extension with HTS. This caution could intensify in the event of destabilizing actions by former HTS officials or shifts in the political posture of key sanctioning states toward Damascus. CBoS previously held capital exceeding that of all private Syrian banks combined, due to its central role in managing public deposits and transactions. It funded major development projects, including a SYP 20 billion loan in 2017 for infrastructure at Marota City in Damascus. As long as HTS remains under UN sanctions, parts of Syria’s banking system are likely to face continued constraints.
In a centralized post-Assad system, ministries and national-level agencies are now the main gatekeepers for public wages and social service delivery, import licensing and customs policy, energy governance and tariff setting, infrastructure tenders and land-use decisions, and sovereign borrowing. Even if only a minority of ministers have direct HTS military backgrounds, and a larger subset has experience in the Syrian Salvation Government—the HTS-aligned civilian administration that formerly governed much of Idlib—this may still present a risk for banks, insurers, and contractors: that funds or economic resources could be made available, “directly or indirectly,” to a listed entity through discretionary state channels.
Senior figures within the state with reported HTS military backgrounds include Ahmad al-Sharaa, the Interim President, as well as several ministers:
- Asaad Hassan al-Shibani, Minister of Foreign Affairs and Expatriates
- Murhaf Abu Qasara, Minister of Defense
- Anas Khattab, Minister of Interior
- Mazhar al-Weis, Minister of Justice.
If we include those with Syrian Salvation Government affiliation, the risk-perception envelope expands to:
- Mohammad Sameh al-Hamoud, Minister of Sports and Youth
- Mustafa Abd al-Razzaq, Minister of Public Works and Housing
- Mohammad Hassan al-Skaff, Minister of Administrative Development
- Mohammad Anjarani, Minister of Local Administration and Environment
- Mohammad al-Bashir, Minister of Energy.
Compliance officers assess sanctions risk not primarily through narrow legal interpretation, but through indicators of proximity, control, and discretionary authority. When ministries appear staffed or influenced by individuals linked to a listed organization, foreign donors, export-credit agencies, and private financiers may fear they cannot reliably separate general budget support from material benefit to a listed network. These concerns are sharper in a transitional system still consolidating command structures, auditing capacity, and procurement oversight.
Reduced willingness to transact with Syrian banks compounds the problem. Banks face heavier compliance burdens and due-diligence checks on clients linked to HTS as they navigate the complex overlapping sanctions regimes. The time and resources required for these checks grow as long as HTS remains listed. In turn, Syrian banks adopt stricter internal compliance thresholds that many local businesses cannot meet. Clients report long waiting times for due-diligence approval and difficulty providing documentation to required standards.
Reconstruction, a sector dominated by state decision-making, faces similar challenges. Companies fear that contracts involving tendering, zoning, or permits may constitute the provision of “economic resources” that could indirectly benefit a listed entity. This drives higher risk premiums, fewer bids, and slower project delivery.
Energy governance is equally affected. Although Western energy sanctions have eased, the UN’s continued listing of HTS can deter upstream investment, electricity-grid rehabilitation, and fuel import financing. Investors may conclude that regulatory decision-making or revenue flows remain vulnerable to capture by networks associated with HTS-linked actors.
On 18 November 2025, the Syrian Petroleum Company (SPC), a state-owned oil exploration and production company, signed a memorandum of understanding (MoU) with US-based ConocoPhillips and Novaterra to expand cooperation in the natural gas sector. Likewise, on 2 December, Syrian President Ahmad al-Sharaa met delegations from US oil major Chevron and the SPC to discuss cooperation in oil and gas exploration fields on Syrian shores. Interest from major international firms can emerge even as compliance concerns persist in the background, which may shape whether such MoUs move beyond the exploratory stage. It remains unclear whether these MoUs will stay at the exploratory level or develop into binding operational agreements.
Humanitarian actors also operate with similar concerns. While the Security Council exempts humanitarian agencies from UN asset freezes—including under the 1267 regime—aid organizations remain cautious about the legal and reputational risks of working in state structures associated with a listed group.
Even Western governments face complications. The UN arms embargo on HTS raises concerns about the end-use of equipment, training, or dual-use support routed through ministries perceived as adjacent to former HTS structures, particularly defense and interior.
The cumulative effect is that the UN’s listing of HTS continues to produce sector-like outcomes by anchoring global compliance at a high level, amplifying reputational risk, and fostering a presumption of institutional entanglement during a centralized transition.
Delisting senior figures may help reduce political tensions, but it does not resolve the underlying structural problem. As long as HTS remains listed, the ministries most associated with it—through personnel history, governance inheritance, or discretionary economic authority—will remain the channels through which a “targeted” designation generates sector-wide constraints on the emerging Syrian state.
Does Today’s HTS Even Meet the 1267 Listing Criteria?
A central question now confronting policymakers is whether the current iteration of HTS still meets the threshold for designation under the 1267 regime. The organization that exists today differs substantially from the one originally listed. Beginning in 2016, HTS publicly severed ties with al-Qaeda, rejected its transnational agenda, and barred al-Qaeda operatives from working in areas under its control. Syria is, in fact, the only context in which an armed group has intentionally dismantled an al-Qaeda branch: Hurras al-Din, once al-Qaeda’s formal affiliate in Syria, formally disbanded in January after sustained pressure from HTS. Since 2020, al-Qaeda has been essentially dormant inside Syria, maintaining no frontline presence and conducting no military operations, though some individuals remain in hiding in the northwest.
For this reason, the relevant timeline for assessing HTS’s eligibility for delisting extends far beyond the recent political transition in Damascus. Its distancing from al-Qaeda began in 2016, and al-Qaeda as an organization had ceased meaningful activity in the country by 2020. During this period, HTS also confronted ISIL with notable force: it detained ISIL members, executed several publicly, and disrupted ISIL cells both before and after the fall of the Assad government.
Although HTS has not expelled all foreign fighters—one of the demands raised by foreign governments—the interim authorities argue that these individuals do not threaten regional or international stability. In January, the government sought to show that it is containing any potential external threat by arresting an Egyptian militant, formerly aligned with HTS against Assad, after he issued threats against Egypt’s president.
These shifts in HTS’s behavior are now embedded in Syria’s broader geopolitical realignment. Following President Sharaa’s visit to Washington on 10 November 2025—the first such visit in nearly eighty years—the US Embassy in Damascus announced that Syria had become the 90th member of the Global Coalition to Defeat ISIL. This development formalized counterterrorism cooperation that had been building quietly for years, including coordination with neighboring Jordan, Iraq, and Lebanon. Joining the coalition required a credible commitment to counter both ISIL and al-Qaeda, directly undermining the premise that HTS or the Syrian state continues to “support” either group.
HTS’s own religious leadership has also endorsed this shift. Abdullah al-Mheissani, HTS’s former chief mufti, issued a fatwa backing Syria’s decision to join the anti-ISIL coalition, describing ISIL as Khawarij, or heretical extremists. His ruling stressed the need to “organize and stabilize decision-making” under the new state so that the ISIL threat cannot serve as a pretext for further foreign intervention. The fatwa is politically significant: senior HTS-linked religious authorities are openly legitimizing cooperation with an international coalition whose explicit mission is to defeat al-Qaeda and ISIL.
For years, Syrian officials and Western diplomats have confirmed privately that HTS and the interim authorities have been working with the US-led coalition to marginalize both al-Qaeda and ISIL. This cooperation began as early as 2016, when HTS, then the de facto authority governing Idlib, was expelling al-Qaeda operatives and targeting ISIL cells. Syria’s formal accession to the anti-ISIL coalition simply codifies a counterterrorism partnership that had already taken shape on the ground. Taken together, these developments raise a real question about whether the HTS of today still meets the 1267 criteria of “association with” al-Qaeda or ISIL.
The Remaining Challenges of Delisting HTS
Even with the substantial transformation of HTS and the growing evidence that it no longer maintains operational links to al-Qaeda or ISIL, significant obstacles remain that may hinder the group’s removal from the 1267 list. These challenges stem less from what HTS is today than from the complexity of the environment in which it operates, and from the concerns of member states tasked with assessing long-term risk.
A UN Monitoring Team report from July 2025 concluded that HTS has no “active ties” to al-Qaeda. Yet the same assessment underscored internal contradictions within the group. According to the report, “many tactical-level individuals [within HTS] hold more extreme views than … [Jawlani] and Interior Minister Anas Khattab, who are generally regarded as more pragmatic than ideological.”
Earlier Monitoring Team findings, published in February 2025, also complicated the picture. While acknowledging that HTS led the campaign that ultimately toppled the Assad regime, the report noted that other listed and non-listed armed groups participated as well. Some of those groups—the Turkistan Islamic Party, Katibat al-Imam al-Bukhari, and Katibat al-Tawhid wal-Jihad—are foreign-fighter organizations embedded in Al-Qaeda’s global network. The report added that although HTS’s senior figures promoted a nationalist agenda, nearly half of HTS’s fighters were reportedly aligned with al-Qaeda’s ideology. For member states, this raises questions about whether HTS can reliably prevent jihadist elements from re-embedding themselves within its structures.
Beyond HTS itself, the broader Syrian landscape also complicates delisting. Authority in Damascus remains fragile, and several pro-government militias—now nominally integrated into state structures—have been implicated in sectarian abuses. Armed groups linked to the Ministry of Defense, including the Sultan Suleiman Shah Brigade and the Hamzat Division, were implicated in sectarian massacres of Alawite civilians on the coast in March. Such incidents raise doubts about whether the new Syrian authorities can be viewed as stable or responsible counterterrorism partners. These concerns grow sharper when set against the presence of foreign jihadists—from China, the Western Balkans, the North Caucasus, and elsewhere—within elements of the Syrian security apparatus. Their loyalties, ideological leanings, and command relationships remain opaque.
Together, these factors explain why many states remain reluctant to support delisting. HTS may have broken with al-Qaeda and ISIL, dismantled jihadist affiliates, and aligned itself with the international coalition against extremism. But the ideological diversity within its ranks, the presence of listed foreign-fighter groups in its past campaigns, and the unsettled security environment surrounding the new Syrian government all feed into a risk assessment that remains cautious.
Annex I: Individuals Listed Under the UN 1267 Regime for Links to al-Nusrah
| Name | Nationality | Other Information |
| Abd Al-Rahman Muhammad Zafir Al-Dubaysi Al-Juhni | Saudi Arabia | A member and regional commander of Jabhat al-Nusrah and a facilitator of foreign recruits for that group. |
| Abdul Mohsen Abdullah Ibrahim Al-Sharikh | Saudi Arabia | A long-time facilitator and financier for al-Qaeda, appointed as a regional leader of al-Nusrah. Reportedly killed in a counterterrorism operation in northwest Syria in October 2015. |
| Ashraf Muhammad Yusif “Uthman” Abd-al-Salam | Jordan | A member of al-Qaeda (QDe.004) as of 2012 and a fighter in the Syrian Arab Republic since early 2014. Provided financial, material, and technological support for al-Qaeda and al-Nusrah. |
| Ayrat Nasimovich Vakhitov | Russia | Member of al-Nusrah; leads a group of 100 fighters. |
| Bassam Ahmad al-Hasri | Syria | Leader of al-Nusrah in southern Syria since July 2016. |
| Haid al-Ali | Kuwait | A Kuwait-based financier, recruiter, and facilitator for the Islamic State in Iraq and the Levant (ISIL) and al-Nusrah. |
| Ayyad Nazmi Salih Khalil | Jordan | Leader of al-Nusrah in the coastal area of Syria since March 2016. |
| Jamal Hussein Hassan Zayniyah | Syria | Leader of al-Nusrah in West Kalamoun (Rural Damascus governorate), Syria. |
| Kevin Jordan Axel Guiavarch | France | French terrorist fighter associated with al-Nusrah and ISIL. Facilitated foreign terrorist fighters travel from France to Syria. Activist in violent propaganda via the Internet. |
| Maysar Ali Musa Abdallah Al-Juburi | Iraq | Reportedly died on 2 April 2025 in Syria. Sharia amir (senior religious authority) of al-Nusrah as of early 2014. |
| Murad Iraklievich Margoshvili | Russia | Associated with al-Nusrah. |
| Nusret Imamovic | Bosnia and Herzegovina | Believed to be fighting with al-Nusrah in Syria and reported to be a leader in the group as of April 2025. |
| Oumar Diaby | Senegal | Leader of an armed group linked to al-Nusrah and a key facilitator for a Syrian foreign terrorist fighter network. Active in terrorist propaganda via the Internet. |
| Sa’d bin Sa’d Muhammad Shiryan al-Ka’bi | Qatar | Qatar-based facilitator who provides financial services to, or in support of, al-Nusrah. |
| Said Arif | Algeria | Reportedly killed in an air strike in Syria on 25 May 2015. A veteran member of the “Chechen Network” (not listed) and other terrorist groups. He was convicted of his role and membership in the Chechen Network in France in 2006. Joined al-Nusrah in October 2013. |
| Shafi Sultan Mohammed al-Ajmi | Kuwait | Fundraiser for al-Nusrah. |
| Shamil Magomedovich Ismailov | Russia | Leader of Jamaat Abu Hanifa, a terrorist group that is part of al-Nusrah, since August 2015. |
Annex II: Listed Entities and Other Groups Related to al-Nusrah
| Name | Other Information |
| Abdalah Azzam Brigades | An armed group that has carried out joint attacks with al-Nusrah. |
| Khatiba al-Tawhid Wal-Jihad (formerly known as Jannat Oshiklari) | A terrorist organization operating under the umbrella of the international terrorist organization al-Nusrah. The group mainly operates in the provinces of Hama, Idlib, and Ladhiqiyah (Latakia), in the Syrian Arab Republic. |
| Khatiba Imam al-Bukhari | Associated with al-Nusrah. Committed terrorist attacks in the Syrian Arab Republic. Redeployed to Northern Afghanistan since 2016 to project attacks against Central Asia countries. |