Modernizing Sanctions To Combat Terrorism

This executive order revokes the 1995 Executive Order 12947 and amends Executive Order 13224 to consolidate and modernize terrorism sanctions authorities. It expands the Treasury and State Departments' powers to block assets and restrict financial access for individuals and entities tied to terrorism, including those who provide material support, receive terrorist training, or are owned or controlled by sanctioned persons.

Federal Register Open PDF 84 FR 48041

Impact dates

Sep 10, 2019
Order effective at 12:01 a.m. eastern daylight time

Key directives

Terminate national emergency declared in EO 12947 and revoke EO 12947
Amend EO 13224 Section 1 to expand blocking criteria for terrorism-related persons
Authorize Treasury to prohibit or restrict correspondent/payable-through accounts of foreign financial institutions facilitating transactions for blocked persons
Amend EO 13224 Section 5 to reference new subsection 1(a)(iii)

Who is ordered

Timeline

Immediate

EO 12947 terminated and revoked
EO 13224 Section 1 amended with expanded blocking criteria
EO effective 12:01 a.m. EDT September 10, 2019

Near term (90d)

Secretary of State and Treasury to implement expanded designation authorities
Foreign financial institutions may face correspondent account restrictions

Long term

Ongoing sanctions enforcement under consolidated framework
Potential expansion of designated persons list under broader criteria

Risks & tensions

Expanded 'material support' and 'owned or controlled' criteria may increase due process concerns for designations
Vague phrase 'significant risk of committing' acts of terrorism in 1(a)(ii)(A) lowers threshold for sanctions without clear procedural safeguards
Foreign financial institutions face compliance burden to avoid correspondent account restrictions
Consolidation of two decades of sanctions authorities centralizes power in Treasury/State discretion