The new law creates a system of targeted financial sanctions in line with international standards.
Somalia has enacted Law No. 4, the Financial Sanctions Regulation Act. The law establishes a system of targeted financial sanctions against individuals and entities suspected of financing terrorism.
The Act was enacted to strengthen Somalia's ability to prevent terrorism financing and to comply with United Nations Security Council resolutions. Its purpose is to give authorities clear procedures for designating individuals, freezing assets, and handling appeals.
Law No. 4, the Financial Sanctions Regulation Act was enacted and entered into force on March 8, 2023.
Cutting off the flow of funds is one of the most effective ways to disrupt terrorism. This law gives Somalia the legal tools to do so while aligning its practice with international standards.
Article 2 (Objective) sets out the law's aim of enabling Somalia to operate a strict financial sanctions system and to comply with UN Security Council resolutions. Article 4 (Offence of Financing Terrorism) defines the underlying crime, covering the provision or collection of funds to support terrorist acts.
The law sets out how sanctions are applied. Article 6 (Identification and Designation) describes how individuals and entities are identified, designated, and notified, and Article 7 (Freezing of Funds and Assets) provides that the assets of designated persons must be frozen immediately.
Importantly, the law also protects the rights of those affected. Article 8 (Right to Apply Against Designation) gives designated persons the right to appeal, first to the responsible committee and then to the Supreme Court, and Article 9 (Claims Against Designation) sets out how an asset freeze may be lifted.
Humanitarian and oversight considerations are built in. Article 10 (Funds Exempted for Humanitarian Reasons) exempts funds needed for basic living and legal expenses, while Article 11 (Oversight and Monitoring Bodies) empowers the relevant bodies to require reports to ensure compliance.
This law is important because it equips Somalia to act against terrorism financing in a way that meets international expectations. Clear designation and asset-freezing procedures strengthen national security, while appeal rights and humanitarian exemptions help protect due process.
“Effective sanctions against terrorism financing must be both firm and fair. This Act gives Somalia clear powers to freeze assets while preserving the right to appeal and exemptions for humanitarian needs. Careful, even-handed application of these procedures will be vital both to national security and to maintaining confidence in the rule of law.”
, Hawa A. Wehelie, JD (Juris Doctor), MBA (Master of Business Administration)
Managing Partner at Mogadishu Law Office
This release is provided for general information and does not constitute legal advice. Professional legal advice should be obtained before acting on any matter discussed here.