Executive Order 13224 (2001)

Executive Order 13224 is a United States emergency authority for blocking property of persons connected to terrorism. President George W. Bush issued it on 23 September 2001 under the International Emergency Economic Powers Act and related statutes. Executive Order 13886 materially amended its designation criteria and consequences in September 2019. OFAC implements the programme through 31 C.F.R. part 594.

Authority and designation

The original annex named organisations and individuals. The order also authorised the Secretary of State and Secretary of the Treasury, in consultation as required, to designate additional persons under stated criteria. Executive Order 13886 modernised those criteria, including persons determined to have committed or attempted terrorism, to pose a significant risk of committing terrorism, or to be leaders, officials, agents, owners or controllers of specified persons. The exact prong must be identified in the designation notice.

A designation is an administrative blocking action. It does not itself prove criminal guilt, membership of a listed group or liability for every act attributed to that group. Criminal prosecution, immigration action, United Nations listing and designation as a Foreign Terrorist Organization are separate legal processes.

Blocking effect and compliance

Property and interests in property of a blocked person that are in the United States or within the possession or control of a United States person must be blocked and reported to OFAC. Transactions involving blocked property are prohibited unless authorised. OFAC's 50 Percent Rule can extend blocking to an entity owned, directly or indirectly, 50 per cent or more in aggregate by one or more blocked persons even if the entity is not separately named.

Blocking is not confiscation. Title ordinarily remains with the owner while the property is immobilised. A rejected transaction is also different from blocked property. Investigation, civil enforcement and criminal prosecution have different standards and decision-makers.

Humanitarian and multilateral boundaries

The regulations contain licences and OFAC issues general licences for specified activity. In 2022 and 2023, Treasury implemented humanitarian authorisations following UN Security Council Resolution 2664, including for certain transactions involving official business, humanitarian activity and basic human needs. Their scope and exclusions must be checked against current text rather than assumed from the label "humanitarian".

The United States programme interacts with UN Security Council sanctions concerning ISIL and Al-Qaida, but the lists are not coextensive. A person may be blocked under US authority without being on a UN list, and UN obligations require their own domestic implementation.

List screening must therefore preserve the authority and programme tag.

Strategic significance and limits

The order uses access to dollar clearing, correspondent banking and assets within US control to disrupt funding and isolate designated networks. Third-country institutions may also reduce exposure because of legal or reputational risk. That wider response is not itself proof that the order has global jurisdiction or that every affected transaction financed terrorism.

See also

Office of Foreign Assets Control (United States) · Asset freeze · Specially Designated Nationals and Blocked Persons List · UNSCR 1373 (2001) · Compliance cascade · Financial warfare

Sources

1. Executive Order 13224, Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism, 23 September 2001.
2. Executive Order 13886, Modernizing Sanctions To Combat Terrorism, 10 September 2019.
3. Department of the Treasury, Global Terrorism Sanctions Regulations, 31 C.F.R. part 594, checked 30 July 2026.
4. Office of Foreign Assets Control, Counter Terrorism Sanctions, checked 30 July 2026.