The United States is seeking a UN resolution demanding that countries adopt laws making it a serious crime to enlist as a foreign fighter for Islamist groups in Iraq and Syria.

The draft resolution, which has been circulated to Security Council members, is expected to be adopted at a special session of the top world body chaired by US President Barack Obama on September 24.

Under the measure, governments would take action against their nationals who travel or make plans to travel to a country "for the purpose of the perpetration, planning, or preparation of, or participation in terrorist acts."

It would also make it illegal to collect funds or help organize the travel of foreign fighters for groups like the Islamic State in Iraq and the Levant (ISIL), which is on the UN terror list.

The text obtained by AFP demands that "all states shall ensure that their domestic laws and regulations establish serious criminal offenses sufficient to provide the ability to prosecute and to penalize in a manner duly reflecting the seriousness of the offense."

About 12,000 foreign fighters have traveled to Syria and recently to Iraq from 74 countries, in the biggest such mobilization since the Afghan war of the 1980s, according to the London-based International Center for the Study of Radicalisation (ICSR), which tracks foreign fighters.

The UN Security Council last month adopted a resolution aimed at weakening Islamists in Iraq and Syria by cutting off financing and the flow of foreign fighters.

The US-drafted resolution goes further by putting the onus on governments to draft legislation allowing them to take action on their territory or use existing laws to address the threat of foreign fighters.

"The resolution will impose new binding obligations on countries to take action against foreign fighters, to prevent the facilitation of travel by foreign fighters and stop suspects," a US official said.

The resolution would fall under Chapter 7 of the UN charter, which means the measures could be enforced by economic sanctions or military force.

- Mobilization among biggest ever -

With 12,000 fighters mobilized over the past three years compared to 20,000 in Afghanistan over a decade, the movement is "well on track to becoming the most significant mobilization of foreign fighters that has ever taken place in living memory," said Peter Neumann, director of the ICRS.

The overwhelming majority of foreign fighters, up to 75 percent, are from the Middle East and Arab countries, with Saudi Arabia, Tunisia and Morocco topping the list.

About 700 foreign fighters are from France, followed by some 500 from Britain, 400 from Germany and 300 from Belgium, according to Neumann.

The call for action to stem the flow of foreign fighters is fueled by fears that new terror networks will emerge from the Syria-Iraq front, much in the same way that the September 11, 2001 attacks were linked to the Taliban and Al-Qaeda in Afghanistan.

Many countries like France and Britain have already moved to enact measures to clamp down on aspiring jihadists, amid much concern over the need to balance security and protect civil liberties.

The new measure will put pressure on countries like Turkey, the main transit point for foreign fighters, as well as Saudi Arabia and other key suppliers.

The draft demands that countries prevent entry to individuals suspected of taking part in foreign fighting and requires that airlines provide passenger information to detect the departure of a foreign fighter.

It also calls on governments to develop strategies to counter violent extremism, by reaching out to local communities.

The US push for world action against jihadist recruits comes as the United States is seeking to form a broad coalition to defeat the Islamists that have overrun large parts of Iraq and Syria.