Over the years, Libyan government officials persisted in working with U.S. partners to combat terrorism, although cracked security institutions limited direct collaboration. Following the collapse of the self-styled Libyan National Army’s (LNA’s) military assault on western Libya in 2019-20, UN-facilitated talks established a new nominally unified interim executive authority, the Government of National Unity (GNU).

Despite the political tension, terrorist groups such as ISIS and al-Qa’ida in the Islamic Maghreb (AQIM) have been incapable of significantly regrouping.  While terrorist groups control no region in Libya and are significantly impaired in terms of numbers and capacity, they remain a threat. Components of the GNU are dedicated and willing U.S. counterterrorism partners, although the GNU’s ability to eliminate terrorist safe havens, counter-terrorist financing, prevent the flow of FTFs, and ensure effective counterproliferation measures across Libya’s territory was restricted. The LNA deviated from terrorism in the East and South of the country, but its counterterrorism gains were limited to areas under its direct control.

The GNU retained the Government of National Accord’s Counterterrorism strategy and its national CT coordinator. In the procedure, however, under the term of the GNU, coordination between relevant management still largely occurs on an ad hoc basis, and an undertaking plan for the new strategy has yet to be promulgated. Throughout 2021 the GNU performed CT operations in the country, and the LNA opposed terrorism in areas under its control.

Moreover, Libyan authorities did not pass or enforce any counterterrorism legislation in 2021. Libya lacks a sweeping counterterrorism law, although the Libyan penal code outlaws offenses that may threaten national security, including terrorism, the advancement of terrorist acts, and the handling of funds in support of such acts.

Libya has endorsed the African Union’s (AU’s) Convention on the Prevention and Combating of Terrorism, which directs states to criminalize terrorist acts under their national laws. The GNU persisted in seeking international support to combat ISIS-Libya and AQIM.

Despite Libya’s disconnected security institutions and ongoing political strife, the GNU launched operations to disrupt terrorist groups. In September 2021, the GNU announced the detention of senior ISIS leader Mubarak al-Kharmi along with two other militants in the western city of Bani Walid. That same month, LNA squads captured suspected ISIS member Ali al-Ajili al-Hasnawi in Brak al-Shati.

Libya is also a member of MENAFATF. Libya is also a member of the Defeat-ISIS CIFG.  The Central Bank of Libya experienced a detailed gap analysis of the Libyan Anti-Money Laundering and Terrorist Financing Law No. 1013 of 2017 and recognized numerous strategic weaknesses. The CBL also donated to the development of a regulatory framework to support and ensure better compliance with international standards and relevant regulations governing anti-money laundering and counter-financing of terrorism.

Further, CBL initiated the expansion of a set of instructions for banks and financial institutions that present accounts to nonprofit organizations. The instructions aim to raise the awareness and capacity of these banks and institutions regarding hunt and reporting on possible money laundering and terrorist financing activities.