Daesh and Al-Qaeda Sanctions List: 21 entries updated in August 2026

Key data

If your company operates in the financial sector or is required to verify international sanctions lists, this update affects you from yesterday. The Implementation Regulation (EU) 2026/1965, published on August 27, 2026 in the EU Official Journal, amends for the 360th time Regulation (EC) No. 881/2002, updating the identifying data of 21 entries in Annex I of the list of persons and entities linked to Daesh and Al-Qaeda.

The origin of the changes is a decision by the UN Security Council Sanctions Committee of August 18, 2026, adopted under resolutions 1267 (1999), 1989 (2011) and 2253 (2015). The EU transfers these modifications to its own regulatory framework with immediate effect in all Member States.

What does this regulation establish?

Regulation (EC) No. 881/2002 is the EU instrument that imposes specific restrictive measures — fundamentally the freezing of funds and economic resources — on persons and entities associated with Daesh (ISIL) and Al-Qaeda. Its Annex I is the operational list: the one that banks, insurance companies, fund managers and any operator moving money or assets must consult.

This 360th amendment updates 21 entries already existing in that Annex. The types of changes included are:

• Correction or addition of aliases and alternative names of listed persons
• Update of dates and places of birth
• Correction or addition of nationalities
• Incorporation of additional data, including confirmation of death of some individuals

The confirmation of death of certain listed individuals is relevant from an operational point of view: even if the individual has died, their entry may be maintained on the list to block assets linked to their estate or network. Operators must treat these entries according to the specific instructions for each case.

The regulation is directly applicable in all Member States from the day following its publication, without need for national transposition.

Economic and operational impact

The impact is not direct cost in the form of a fee or automatic sanction, but rather operational and compliance risk. The consequences of failing to update screening systems in time can be serious:

• Processing of prohibited transactions: if a system does not incorporate the updated data of the 21 entries, it may execute operations with sanctioned persons or entities, which constitutes a direct breach of Regulation (EC) 881/2002.
• Administrative and criminal sanctions: competent national authorities may impose significant penalties for non-compliance with asset freezing measures.
• Reputational risk: operational linkage with listed entities, even if unintentional, generates reputational damage that is difficult to manage.
• Remediation cost: detecting and reversing operations already executed with listed entities is costly in terms of time, legal resources and relationship with the regulator.

The fact that this is the 360th amendment to this regulation illustrates how frequently these updates occur. Operators who do not have automated processes for updating lists assume significant cumulative risk.

Who does it affect?

• Credit institutions and banks: required to block funds and economic resources of listed parties and not to make funds available to them.
• Insurance and reinsurance companies: must verify that no counterparty appears in Annex I before executing payments or underwriting policies.
• Investment fund managers and payment institutions: any transfer of assets requires prior screening against the updated list.
• Investment services firms (ISFs): required to verify clients, counterparties and ultimate beneficial owners.
• Foreign trade operators and logistics companies: when managing payments or assets linked to third parties, they must verify that they do not appear on the list.
• Compliance departments and compliance officers of any company with obligations regarding international sanctions.
• Legal advisors and consultants providing services to the above sectors.

Practical example

A Spanish bank processes thousands of international transfers daily. Its screening system compares the data of senders and beneficiaries against the list in Annex I of Regulation (EC) 881/2002. Until August 27, 2026, the database of its sanctions list provider contained the previous data of the 21 entries now modified.

If the bank does not update its system before processing operations on August 28, it may fail to detect an individual whose alias has been corrected or expanded in this update. The result: a transaction executed with a sanctioned party, direct breach of the regulation, obligation to notify the competent authority and opening of a sanctioning file.

The solution is simple in theory but critical in practice: confirm with your sanctions list provider that the August 28, 2026 update is already incorporated and that the 21 modified records reflect the new aliases, dates, nationalities and death data.

What should companies do now?

1. Verify the sanctions list provider update: contact your sanctions screening provider today and confirm that they have incorporated the changes from Implementation Regulation (EU) 2026/1965, in force since August 28, 2026.
2. Review the 21 modified entries in Annex I: access the regulation text directly in the EU Official Journal to identify which specific entries have changed and what data has been updated.
3. Execute retroactive screening if necessary: if there is a risk that recent operations have been processed with outdated data, launch a review of transactions executed since August 28.
4. Update internal compliance procedures: document the review performed and update your sanctions compliance program records to reflect this amendment.
5. Establish automatic alerts for future amendments: given that this regulation has already accumulated 360 amendments, automate the tracking of new updates to Annex I to avoid delays in incorporating changes.
6. Inform operations and front office teams: ensure that the teams executing transactions are aware of the update and know how to act if they detect a match with a listed entity.

Official source

Consult full regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32026R1965