Afghanistan central bank reserve freeze (2021-present)

Da Afghanistan Bank lost access to foreign reserves after the Taliban takeover on 15 August 2021, first through custody, recognition and sanctions uncertainty and later through direct United States policy. The United States subsequently blocked United States-held property under Executive Order 14064 and transferred USD 3.5 billion to the Swiss-based Fund for the Afghan People. Sovereign ownership, custody, execution immunity, conditional access and humanitarian consequence are separate questions.

Loss of access and policy sequence

Da Afghanistan Bank held most of its reserve assets abroad, including approximately USD 7 billion in the United States and additional assets in other jurisdictions. The initial interruption followed the collapse of the recognised Afghan government. Custodians faced sanctions, recognition and authority questions about who could instruct the accounts. That first phase should not be described as a fully designed compellence campaign.

United States policy became direct on 11 February 2022. Executive Order 14064 blocked specified DAB property held in the United States and directed steps to protect part of it for the Afghan people. The order did not itself make the Taliban the owner of DAB's assets or transfer the entire approximately USD 7 billion to one destination.

The United States and partners announced the Afghan Fund on 14 September 2022. USD 3.5 billion was transferred for custody in an account at the Bank for International Settlements under a Swiss foundation structure. The Fund's official overview reports that investment earnings raised its assets above USD 3.9 billion by December 2024. Original principal, investment value and valuation date must remain distinct.

The Fund's June 2025 board statement records approval of audited financial statements. Conditions for access or return include central-bank independence and financial-integrity safeguards. These are institutional access conditions, not proof of a general demand that the Taliban change every unrelated policy. Disbursement and governance status require a fresh check at publication.

Litigation and execution immunity

The other United States-held DAB assets became subject to litigation by judgment creditors seeking execution. They were not allocated to September 11 claimants merely because claims were filed. United States courts held that the central-bank assets were immune from attachment. The Second Circuit affirmed that result on 26 August 2025, and the court denied rehearing en banc on 19 March 2026.

Execution immunity does not decide recognition of the Taliban, operational access by DAB, the Fund's governance or the final disposition of every reserve asset. Those legal and policy questions must not be collapsed into confiscation, donation or return.

Sanctions, central-bank functions and humanitarian conditions

United States Treasury Afghanistan-related sanctions guidance sets the operative sanctions and licensing context as at 29 July 2026. United Nations Security Council Resolution 2615 created a humanitarian exemption within the UN sanctions regime. It did not release DAB reserves held in the United States or decide their ownership.

Reserve inaccessibility constrained DAB's options for foreign-exchange operations, liquidity support and confidence management. It occurred alongside the loss of external aid, banking dysfunction, drought, conflict effects, large population returns and restrictions on women. The World Bank's May 2026 Economic Monitor reports modest output growth alongside falling living standards and structural fragility. The United Nations June 2026 report records severe humanitarian and political conditions. Neither source supports assigning the whole crisis to one reserve measure.

Assessment

The policy has denied the de facto authorities access and preserved nominal assets outside Afghanistan. The intended stabilisation benefit remains unrealised while the reserves cannot support ordinary central-bank functions. A broader claim of successful regime compellence is not established.

This is a post-conflict financial and recognition case with a direct state nexus after February 2022. It is not wartime economic action. Its humanitarian assessment must remain multi-causal, distinguish state assets from the de facto authority and avoid treating asset preservation as proof of social benefit.

See also

Central-bank reserve immobilisation · Da Afghanistan Bank · Humanitarian cost of sanctions · Central-bank reserve immobilisation and confiscation · United States freeze of Iranian government assets during the hostage crisis (1979-1981) · Coalition immobilisation of Central Bank of Russia reserves (2022-present) · Over-compliance (de-risking) · Financial warfare

Sources

• Office of the Federal Register, "Executive Order 14064, Protecting Certain Property of Da Afghanistan Bank for the Benefit of the People of Afghanistan" (11 February 2022).
• United States Department of the Treasury, Office of Foreign Assets Control, "Afghanistan-Related Sanctions," accessed 29 July 2026.
• United States Department of the Treasury and Department of State, "The United States and Partners Announce Establishment of Fund for the People of Afghanistan" (14 September 2022).
• Fund for the Afghan People, "Foundation Overview," accessed 29 July 2026.
• Fund for the Afghan People, "Statement on the Ninth Board Meeting" (30 June 2025).
• United States Court of Appeals for the Second Circuit, Havlish v. Taliban, Panel Opinion (26 August 2025).
• United States Court of Appeals for the Second Circuit, Havlish v. Taliban, Denial of Rehearing En Banc (19 March 2026).
• World Bank, Afghanistan Economic Monitor, May 2026 (May 2026).
• United Nations Assistance Mission in Afghanistan, Report of the Secretary-General, A/80/745-S/2026/431 (8 June 2026).
• United Nations Security Council, "Resolution 2615 and Afghanistan Humanitarian Exemption" (22 December 2021).