Executive Order 13224, "Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism," was issued by President George W. Bush on September 23, 2001, twelve days after the September 11 attacks. It is one of the principal legal instruments used by the U.S. Office of Foreign Assets Control (OFAC) to impose counterterrorism sanctions on individuals, entities, and networks.
The order invokes authority under the International Emergency Economic Powers Act (IEEPA), the National Emergencies Act, and section 5 of the United Nations Participation Act. It blocks all property and interests in property of designated persons that come within U.S. jurisdiction, and prohibits U.S. persons from transacting with them. An initial annex named 27 individuals and entities, including Osama bin Laden, al-Qaida, and several Taliban figures.
Designation criteria are broad. The Secretary of State (in consultation with Treasury and the Attorney General) may designate foreign persons determined to have committed, or to pose a significant risk of committing, acts of terrorism threatening U.S. nationals or security. The Secretary of the Treasury may designate persons determined to be owned or controlled by, to act for, or to assist, sponsor, or provide financial, material, or technological support to already-designated parties. This "material support" prong is the workhorse of the program and has been used against financiers, charities, hawala networks, and front companies.
Designations appear on OFAC's Specially Designated Nationals and Blocked Persons (SDN) List with the tag [SDGT] ("Specially Designated Global Terrorist"). The order was amended by EO 13268 (2002), which removed Taliban-specific provisions after a separate national emergency was terminated, and by EO 13886 (2019), which expanded designation criteria, added secondary sanctions authority against foreign financial institutions, and raised civil penalty caps. Delisting is possible through OFAC's administrative reconsideration process, though successful petitions are rare. EO 13224 operates alongside, but is distinct from, UN Security Council 1267/1989/2253 ISIL-Al-Qaida sanctions and the State Department's Foreign Terrorist Organization (FTO) list under INA §219.
Example
In April 2019, OFAC used EO 13224 to designate Iran's Islamic Revolutionary Guard Corps (IRGC) as a Specially Designated Global Terrorist, the first time a state entity received that label.
Frequently asked questions
Foreign persons determined to commit or threaten terrorism, plus any person—foreign or domestic—who materially supports, is owned or controlled by, or acts for an already-designated party.
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