Country Background

The Libyan Civil War was an armed conflict fought between forces loyal to Libya’s Colonel Muammar Gaddafi, and those seeking to oust him. In 2019 escalations in conflict, in both the south and in the country’s capital Tripoli, saw fighting move into more populated urban areas. In October 2020, the Government of National Accord (GNA) and the Libyan National Army of the General Command of the Armed Forces signed a ceasefire agreement. In March 2021, the Government of National Unity (GNU) formed a provisional government. An election is scheduled for June 2022.

What Nonprofits Need to Know

Below in the blue is an overview of the humanitarian and peacebuilding needs in Libya. In the red are the primary sanctioned groups presently operating there. Because U.S. law prohibits the provision of “material support” to listed terrorists individuals and groups as well as engaging in trade with sanctioned persons and entities, the presence of these groups and sanctions programs can impact the delivery of aid and peacebuilding programs. The list below is non-exhaustive and changes frequently, so it is important for nonprofits to check all partners and those with whom they engage in transactions against, at a minimum, the U.S. Specially Designated National (SDN) and the United Nations Security Council Consolidated lists. Below the charts is information on OFAC licenses, where applicable, and links to our research and advocacy, and other relevant information.

Libya 1

Humanitarian & Peacebuilding Needs

According to the latest Humanitarian Needs Overview by the Office for the Coordination of Humanitarian Affairs (OCHA), 800,000 people are in need of humanitarian assistance in Libya, though 1.5 million are projected to need assistance in 2022.

Food Security and Nutrition: As of December 2021, over 511,000 people were estimated to be food insecure and in need of food assistance.

Disease and Healthcare: As of December 2021, over 803,000 people lacked adequate access to healthcare services, with up to 90 percent of the country’s primary healthcare centers remaining closed. Lack of sanitation and hygiene remains a significant challenge for many people, particularly IDPs.

Ongoing Hostilities: Civilian casualties have decreased since the ceasefire agreement was reached in October 2020, but reports of human rights violations continue and ongoing hazards such as booby traps, land mines and explosive remnants pose ongoing risks to civilians.

Displacement: Approximately 213,000 people remain displaced across Libya, 132,000 of whom are in need of humanitarian assistance.

Gender-based violence (GBV): Roughly 153,000 people are most at risk of gender-based violence. Psychosocial and gender-based violence support services are very limited.

al-Qa’ida in the Islamic Maghreb (AQIM): Since 1998, this group’s leadership is headquartered in Algeria, but the group operates throughout Libya. Designated as an FTO by the U.S. More information here.

Ansar al-Sharia groups: Active since June 2012 but officially disbanded in May 2017. Mainly operates in the east, mostly in Benghazi and Darnah. More information here.

Islamic State of Iraq and ash-Sham (ISIS)-Libya: This branch of ISIS was formed in 2014. No longer controls territory in Libya but maintains a low-profile presence throughout much of the country. Designated as an FTO by the U.S. and under the UN ISIL (Da’esh) & Al-Qaida Sanctions List. More information here.

al-Mulathamun Battalion: AMB was originally part of al-Qa’ida in the Islamic Maghreb (AQIM) but became a separate organization in late 2012. It maintains an operational presence throughout Libya and is designated by the U.S. as an FTO. More information here.

Primary Terrorist Presence &
Other Sanctioned Groups

Access overview of Libya Sanctions here. Access overview of UN ISIL (Da’esh) & Al-Qaida Sanctions committee here.

Licenses Offered by the Office of Foreign Assets Control (OFAC)

The Office of Foreign Assets Control (OFAC) within the U.S. Department of Treasury enforces sanctions programs. It has a licensing process that allows transactions with sanctioned entities, including listed terrorist groups, that would otherwise be unlawful. Nonprofits that operate in areas affected by sanctions often apply for licenses from OFAC so that they are able to provide services to civilians in conflict zones around the world without running afoul of U.S. sanctions law, engage in peacebuilding activities and more. Find more information here.

On Feb. 25, 2011, OFAC issued:

  • General License 4 with respect to Investment Funds in Which There Is a Blocked Non-Controlling, Minority Interest of the Government of Libya.
  • General License 5 Authorizing Transactions Related to Certain Oil, Gas, or Petroleum Products Exported from Libya.
  • General License 6 with respect to the Transitional National Council of Libya as the Legitimate Governing Authority for Libya​
  • General License 7A with respect to the Libyan National Oil Corporation and its Subsidiaries.
  • General License 8A with respect to the Government of Libya, its Agencies, Instrumentalities, and Controlled Entities, and the Central Bank of Libya.
  • General License 9 ​with respect to the General National Maritime Transport Company.
  • General License 10 with respect to Arab Turkish Bank and North African International Bank.
  • General License 11 with respect to Unblocking the Government of Libya, its Agencies, Instrumentalities, and Controlled Entities, and the Central Bank of Libya, With Certain Exceptions.

For specific transactions not covered by the general licenses, specific licenses are required. You can apply for an OFAC License Online to get authorization from OFAC to engage in a transaction that otherwise would be prohibited.

Policy Reform

The Charity & Security Network advocates for change in national security measures to better support nonprofits working around the world. In fragile contexts, counterterrorism measures often impede humanitarian, development, and peacebuilding organizations from accessing finance for their programs and serving populations in need. Find out more on our key issues below:

  • Find more information on Material Support here.
  • Find more information on Financial Access here.

Last updated: April 29, 2022