Sanctions: Informal Interactive Dialogue on the Focal Point for Delisting
Tomorrow morning (2 October), Security Council members will convene for an informal interactive dialogue (IID) titled “From Adoption to Action: Focal Point Mechanism and the strengthening of an effective UN sanctions architecture”. Greece, the Council’s president in October, is organising the meeting, with co-sponsorship by Pakistan. The expected briefer is Yvonne Ching Ling Lee (Singapore), who was appointed as the Focal Point for Delisting on 11 June and assumed her post on 1 September. The IID is apparently being convened to highlight Lee’s appointment—which comes about two years after the adoption of resolution 2744 of 19 July 2024 that strengthened the Focal Point mechanism—and to emphasise the importance of the mechanism for the implementation and effectiveness of UN sanctions regimes.
Background
As the number of UN sanctions regimes expanded in the 1990s following the end of the Cold War, concerns emerged about the lack of consistency, transparency, and redress mechanisms in the regimes’ listing and delisting procedures, which threatened the due process rights of designated entities and individuals. To address this issue, the Security Council adopted resolution 1730 of 19 December 2006, which established the Focal Point for Delisting as a Secretariat mechanism to receive delisting requests from individuals and entities on UN sanctions lists and to facilitate consultations between the relevant member states and sanctions committees.
The Focal Point was conceived as a coordination channel rather than a review body, and it was not authorised to advise independently on or recommend delisting decisions, which remained the prerogative of relevant committee members. Due process concerns therefore remained, particularly in relation to what was then known as the 1267 Al-Qaida and Taliban sanctions regime—now the 1267/1989/2253 Islamic State in Iraq and the Levant (ISIL/Da’esh) and Al-Qaida regime—which was, and remains, the largest UN sanctions regime. Consequently, the Council adopted resolution 1904 of 17 December 2009, which created an Office of the Ombudsperson to receive and recommend action on requests for delisting from the 1267/1989/2253 regime specifically. The Ombudsperson remains the only such redress mechanism with independent review authority—which committee members can overturn only by consensus—and proposals to extend this mechanism to all regimes have faced opposition from some permanent members.
Other members have therefore pursued alternative strategies to further strengthen due process. In 2024, the Council unanimously adopted resolution 2744, co-penned by then-Council member Malta and the US, which expanded the Focal Point’s mandate. An annex to the resolution sets out a more proactive process for the mechanism upon receipt of listing requests, including information-gathering, dialogue with petitioners and relevant states, and submission of a “comprehensive report” to the relevant committee—although the mechanism is still not mandated to make recommendations. Resolution 2744 also re-established an Informal Working Group (IWG) of the Security Council on General UN Security Council Sanctions Issues, following a proposal by China during the negotiations. While the IWG does not currently have a chair due to the ongoing impasse in the allocation of subsidiary body chairs, Greece and Pakistan co-chaired it last year.
Implementation of resolution 2744 has been slow, particularly the appointment of a new Focal Point. The text requested the Secretary-General, in consultation with the IWG, to make the appointment within three months, but Council members apparently disagreed over candidates to fill the post, delaying the process. In a letter dated 6 October 2025, the Group of Like-Minded States on Targeted Sanctions urged the Security Council to “reach an agreement on the appointment of a new Focal Point with no further delay”. On 11 June, nearly two years after the adoption of resolution 2744, the Secretary-General announced the appointment of Lee to the position.
Tomorrow’s Meeting
The co-organisers have circulated a concept note to Council members ahead of tomorrow’s meeting, which apparently says that the IID is intended to welcome Lee’s appointment, raise awareness of the Focal Point’s mandate and procedures, and give Council members an opportunity to discuss how to support the Focal Point’s work. In addition to processing delisting requests under its expanded mandate, the concept note emphasises that the Focal Point has other tasks, including receiving communications from individuals claiming to have been subjected to the sanctions measures due to false or mistaken identity, forwarding exemption requests to the 1267/1989/2253 Sanctions Committee and the 1988 Afghanistan Sanctions Committee, and receiving communications from individuals removed from the ISIL/Da’esh and Al-Qaida Sanctions List.
The concept note proposes the following questions to guide tomorrow’s discussion:
- How can member states and the UN promote awareness of the Focal Point?
- What can member states do to support its effective functioning, including by providing timely information and facilitating engagement with petitioners?
- How can member states help expedite pending delisting requests under resolution 1730?
- How can member states facilitate the timely sharing of confidential or sensitive information with the Focal Point?
- Do member states expect a significant number of delisting requests from their nationals, and would technical briefings by the Focal Point be useful?
The concept note also flags two challenges. The first is the prolonged absence of chairs of the Council’s subsidiary bodies. Since the mechanism must present its comprehensive reports to sanctions committees and coordinate with them, the continued absence of chairs and committee meetings could hinder progress. The IWG, whose mandate includes monitoring and improving the Focal Point’s operations, has also not been able to function this year.
The second and related challenge that the concept note raises relates to committee guidelines. Resolution 2744 directed all committees other than the 1267/1989/2253 Committee—for which the Ombudsperson remains the applicable delisting mechanism—to revise their guidelines to reflect the Focal Point’s updated mandate. In December 2025, the IWG adopted draft committee guidelines for all other sanctions committees, reflecting the delisting procedures outlined in resolution 2744, but these committees have yet to incorporate them into their own guidelines. It seems that the UN Secretariat is preparing to transmit the guidelines to the sanctions committees so that they can begin this process, which is complicated by the absence of appointed chairs.
Tomorrow, some Council members—such as Denmark, Latvia, and other like-minded members—may stress the importance of due process and press for stronger safeguards in this regard. Others, such as Russia, may caution against expanding the Focal Point’s role at the expense of Committee prerogatives. Speakers may also reiterate calls for the appointment of subsidiary body chairs, which would facilitate the revision of committee guidelines in line with resolution 2744.
Some speakers may seek information from Lee about the delisting requests that are still pending under the original procedures of resolution 1730 and on how these requests will be transitioned to the new process under resolution 2744. Regarding the lack of subsidiary body chairs, members may also ask how the Focal Point intends to coordinate with committees and Council presidencies, which have in some instances assumed the functions of committee chairs during the current impasse.
