UN 1267 Ombudsperson (2009)

The UN 1267 Ombudsperson independently reviews requests to remove individuals, groups, undertakings and entities from the Security Council's ISIL and Al-Qaida sanctions list. Created by Resolution 1904 in 2009, the office operates within the regime imposing asset freezes, travel bans and an arms embargo. Its recommendation process is a safeguard within that system, not a court exercising general jurisdiction over sanctions. [1, paragraph 66 and Annex II; 2]

Mandate and procedure

A petitioner or an authorised representative may approach the office. Member states may not submit an Ombudsperson petition on a listed person's behalf. State requests to the Committee are a distinct route: Resolution 2734 separately addresses a designating state's delisting request. Treating those procedures as interchangeable obscures who may use each mechanism. [1, paragraph 75 and Annex II opening provisions]

The Ombudsperson seeks information from the petitioner, relevant states, UN bodies and the Monitoring Team, facilitates dialogue and prepares a comprehensive report with a recommendation. The ordinary information-gathering and dialogue periods are four and two months respectively, with specified possibilities for extension or shortening. The report evaluates the listing at the time of review. [1, Annex II, paragraphs 1-8]

A recommendation to retain a listing leaves the restrictions in place. Where delisting is recommended, the resolution provides for termination after the Committee's consideration and a 60-day period, unless the Committee reaches consensus to retain the measures or the question is referred to the Security Council through the specified procedure. The office does not unilaterally remove a name. [1, paragraphs 67-68 and Annex II, paragraphs 14-16]

Dated status

Resolution 2734 extended the mandate, which runs to 17 June 2027. Vera Nkwate Ngassa began her tenure on 16 December 2025. The office's status page, checked on 25 October 2026, recorded 116 accepted petitions, 114 completed proceedings and two pending requests. The completed total included one withdrawal and four cases rendered moot; 109 cases had concluded through the Ombudsperson process, with 73 petitions granted and 36 denied. These are petition counts, not a count of distinct listed persons. [1, paragraph 66; 2-4]

The October status page reflects a later position than the report of 14 July 2026, which recorded 115 accepted requests and 113 completed cases. Case 114 was denied in October, while case 116 began on 31 July. Changes in accepted, pending and completed petitions should be read together, with the reporting dates and definitions preserved. [3, paragraphs 5-9; 4, current statistics and cases 114-116]

Strategic significance and limits

The procedure supplies a channel for testing the factual basis for continuing targeted restrictions. It shares the concern with reasons and effective challenge illustrated by Kadi v Council and Commission (ECJ, 2008), but remains institutionally distinct from EU judicial review. Its existence does not establish that all listings are correct or that sanctions achieve their policy objectives. Those are separate evidentiary questions. [1, Annex II; 5, paragraphs 119-134]

Confidentiality is a material limit. State-supplied confidential information may not be disclosed without the state's written consent, and Committee deliberations remain protected. The process provides for a redacted report or reasons to be communicated to the petitioner, subject to its conditions. The July 2026 report recorded 22 information-sharing agreements or arrangements, including one ad hoc arrangement; that dated figure does not measure complete access to intelligence in every case. [1, paragraph 72 and Annex II, paragraphs 7(g), 8, 13 and 16-18; 3, paragraph 18]

The remit concerns the ISIL and Al-Qaida list. It does not authorise the office to decide separate national designations, award damages or resolve all UN sanctions disputes. A change to the UN listing should therefore be distinguished from the legal position under an independent national or regional measure. No finding about the speed of bank or border-system updates follows from a delisting decision alone. [1, paragraphs 66-68 and Annex II]

Sources

1. United Nations Security Council, Resolution 2734 (2024)&l=en&t=pdf), 10 June 2024, paragraphs 66-75 and Annex II.
2. United Nations Security Council, Office of the Ombudsperson, mandate and office-holder statement, accessed 25 October 2026.
3. Office of the Ombudsperson, *Report submitted pursuant to Security Council resolution 2734 (2024)*, S/2026/573, 14 July 2026, paragraphs 3-9 and 18.
4. Office of the Ombudsperson, *Status of Cases*, current statistics and cases 114-116, accessed 25 October 2026.
5. Court of Justice of the European Union, *Commission and others v Kadi*, Joined Cases C-584/10 P, C-593/10 P and C-595/10 P, ECLI:EU:C:2013:518, 18 July 2013, paragraphs 119-134.