David Anderson QC’s 4th annual report on the UK Terrorist Asset-Freezing etc. Act 2010 was published on 15 March 2015. David Anderson QC has been the Independent Reviewer of that Act’s operation since February 2011. His 1st report summarised the Act and its initial period of operation, his subsequent reports have reviewed the Act’s use and made a number of recommendations – see here for blog on his 3rd report. The Act gives effect to both the UK’s obligations to implement UN Security Council Resolution 1373 (UK terrorist designations) and to the EU’s implementing measures (EU designations).
The report notes differing views as to the effectiveness of the Act, the “remarkably low” amount of assets frozen (£61,000 under both lists), and the limited but increasing use of the power (8 new designations in the year to September 2014, which is more than the total number of designations over the previous 3 years). The report also discusses the potentially onerous licensing provisions, the “seemingly intractable” problems of financial institutions refusing to extend their services to individuals and entities which have been de-listed and the impact of sanctions measures on the provision of humanitarian aid to countries under the control of designated groups, the absence of prosecutions for breach of the Act, and the small number of appeals against designations.