Updated Executive Order Provides Enhanced Counterterrorism Sanctions and Targets Foreign Financial Institutions

On September 10, 2019, President Donald Trump issued a revised Executive Order 13224,[1] furnishing the Treasury and State Departments new mechanisms permitting the U.S. Government to better identify and designate perpetrators of terrorism worldwide, especially ones involved in terrorism financing.  Also on September 10, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) used the new authorities in E.O. 13324 to designate a series of terrorist leaders, facilitators, and entities.[2]Treasury designated 15 leaders, individuals, and entities affiliated with terrorist groups.[3]  The action targets entities affiliated with HAMAS, the Islamic State of Iraq and Syria (ISIS), al-Qa’ida, and the Islamic Revolutionary Guard Corps-Qods-Force (IRGC-QF), and combined with actions taken by the State Department, amounts to some of the furthest reaching designations of terrorists and their supporters in the past 15 years.