ExecutiveOrdersEO
EO 13224Executive OrderG.W. Bush · R

Executive Order 13224

Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism

This executive order declares a national emergency and blocks all U.S.-based property and transactions of foreign terrorists, terrorist financiers, and their associates. It authorizes the Secretaries of Treasury and State to designate individuals and entities for sanctions without prior notice, and prohibits any U.S. person from transacting with designated parties.

Federal Register Open PDF 66 FR 49079

Impact dates

  1. Order effective at 12:01 a.m. eastern daylight time; blocking and transaction prohibitions take effect

Key directives

  • Block all property and interests in property of designated foreign persons in the U.S. or under U.S. person control (Section 1)
  • Prohibit all transactions by U.S. persons in blocked property (Section 2(a))
  • Prohibit evasion, avoidance, or conspiracy to violate order (Sections 2(b)-(c))
  • Secretary of State, with Treasury and Attorney General, determines persons who committed or pose significant risk of terrorism (Section 1(b))
  • Secretary of Treasury, with State and Attorney General, determines persons owned/controlled by or acting for designated persons (Section 1(c))
  • Secretary of Treasury, with State and Attorney General, determines persons who assist, sponsor, or provide support to terrorists (Section 1(d)(i))
  • Secretary of Treasury may take alternative actions short of full blocking for Section 1(d) designees (Section 5)
  • All agencies directed to take appropriate measures to carry out order (Section 7)
  • Secretary of Treasury authorized to promulgate rules and regulations (Section 7)
  • No prior notice required for listing or determination (Section 10)

Who is ordered

Timeline

Immediate

  • Blocking of property for persons listed in Annex effective 12:01 a.m. EDT September 24, 2001
  • Prohibition on all transactions with designated persons takes effect
  • No prior notice required for designations

Near term (90d)

  • Secretary of Treasury to promulgate implementing rules and regulations
  • Interagency coordination for international cooperation and intelligence sharing
  • Potential additional designations under sections 1(b)-(d)

Long term

  • Ongoing sanctions enforcement and designation regime
  • Bilateral and multilateral agreements for counter-terrorism financing
  • Enduring legal framework for U.S. counter-terrorism financial sanctions

Risks & tensions

  • No prior notice requirement (Section 10) and broad designation authority raise due process concerns for designated persons
  • Vague 'otherwise associated with' standard in Section 1(d)(ii) creates uncertainty about scope of liability
  • Potential for overreach affecting humanitarian organizations and innocent financial intermediaries
  • Reliance on classified intelligence for designations limits judicial review and challenge mechanisms
  • International coordination burden on financial institutions for compliance and reporting
  • Conflict with normal contractual and licensing rights explicitly overridden by order
Executive Order 13224: Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism · Executive Orders