The Kingdom of Saudi Arabia's National Procedures
Delisting Request Information
On the 19th of July 2024, the Security Council adopted resolution 2744 (2024), introducing new procedures for the consideration of delisting requested submitted by individuals, groups, undertakings or entities designated on the lists of the sanctions committees established by the Security Council, with the exception of the ISIL (Da'esh) and Al-Qaida Sanctions Committee list, which remains under the purview of the Office of Ombudsperson.
Article 15 of the Mechanism for Implementing Security Council Resolutions under Chapter VII of the United Nations Charter, which are related to the prevention of proliferation of weapons of mass destruction and its financing, stipulates the following:
- Any person or entity listed by the Sanctions Committee or Security Council Resolution who is of Saudi nationality or has a place of business or residence in the Kingdom of Saudi Arabia may submit a request to be omitted from the supervisory authorities, who shall then transfer the request to the Ministry of Foreign Affairs to be sent to the United Nations or directly to the Focal Point for Delisting at the United Nations.
What should be included in a delisting request to the UNSCR 1718 Sanctions Committee?
Delisting requests should contain the following information:
- explanation as to why the designation does not or no longer meets the Listing Criteria (paragraph 8(d) and/or 8(e) of resolution 1718 (2006) through countering the reasons for listing as stated in the list entry for that particular individual or entity);
- the designee's current occupation and/or activities, and any other relevant information;
- any documentation supporting the request can be referred to and/or attached together with the explanation of its relevance, where appropriate.
For a deceased individual, the delisting request shall be submitted either directly to the Committee by a State, or through the Focal Point for Delisting by his/her legal beneficiary, together with an official documentation certifying that status. The statement of case supporting the delisting request shall include the following information:
- death certificate or similar official documentation confirming the death whenever possible;
- whether or not any legal beneficiary of the deceased's estate or any joint owner of his /her assets is on the Sanctions Lists as well.
How to make a delisting request?
Delisting requests can be submitted either to the Committee or through the Focal Point for Delisting[1].
If the petitioner submits the petition to the State of residence or nationality, the following procedure should be followed:
- The State to which a petition is submitted (the petitioned State) should review all relevant information and then approach bilaterally the designating State(s) to seek additional information and to hold consultations on the delisting request;
- The designating State(s) may also request additional information from the petitioner's State of nationality or residence. The petitioned and the designating State(s) may, as appropriate, consult with the Chair during the course of any such bilateral consultations;
- If, after reviewing any additional information, the petitioned State wishes to pursue a delisting request, it should seek to persuade the designating State(s) to submit jointly or separately a request for delisting to the Committee. The petitioned State may, without an accompanying request from the designating State(s), submit a request for delisting to the Committee.
Please address delisting requests to the Chair of the UNSCR 1718 Committee Chair.
What should be included in a delisting request to the UNSCR 1737 Sanctions Committee?
Delisting requests should include a narrative description of the information explaining:
- how the individuals or entities are not or no longer engaged in, directly associated with, or providing support for Iran's proliferation sensitive nuclear activities or for the development of nuclear weapon delivery systems; or
- in which manner they are not or no longer acting on behalf of such individuals and entities or at their direction or are not or no longer owned or controlled by them; or
- how they have not or no longer assisted designated persons or entities in evading sanctions or in violating the provisions of Security Council resolutions 1737 (2006), 1747 (2007), 1803 (2008), or 1929 (2010).
For a deceased individual, the delisting request shall be submitted either directly to the Committee by a State, or through the Focal Point for Delisting by his/her legal beneficiary, to the extent possible with an official documentation certifying that status.
The statement of case supporting the delisting request shall include, if possible, a death certificate or similar official documentation confirming the death. The submitting State or the petitioner should also ascertain and inform the Committee whether or not any legal beneficiary of the deceased's estate or any joint owner of his/her assets is on the list.
How to make a delisting request?
The delisting requests can be submitted either to the Committee or through the Focal Point for Delisting.
Please address the delisting requests to the Chair of the 1737 Sanctions Committee.
Important Note
As stipulated under Article 14 of the aforementioned mechanism, when a false positive occurs (where a person or entity is wrongfully subject to financial sanctions measures [such as an asset freeze], and they assert they are not the intended target), the Permanent Committee has the right to provide instructions to amend the freezing measure (in accordance with Article 3 of the Mechanism). The Permanent Committee shall inform any person – through regulators – who filed this request regarding amending freezing measures or lifting it. If the Committee decided to reject a request filed according to this Article, the applicant may file a request to the competent court to look into the Permanent Committee's resolution with (30) days from the date of receiving the notification of its' decision.
[1] If applying for a delisting request through the Focal Point for Delisting, please refer to their website in order to obtain the necessary information on the required documents for the request.
