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Enhanced counterterrorism sanctions authority exercised

Treasury has announced that OFAC used newly enhanced counterterrorism sanctions authorities on Tuesday to designate a series of terrorist leaders, facilitators, and entities. Equipped with new tools from recently updated Executive Order 13224, Treasury designated 15 leaders, individuals, and entities affiliated with terror groups. That action targets a wide array of groups, including 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.

The amended Executive Order provides the Treasury and State Departments new tools allowing the U.S. to better identify and designate terrorists worldwide. The order now:

  • Contains new designation criteria that allows the U.S. Government to more efficiently target leaders or officials of terrorists groups as well as individuals who participate in terrorist training;
  • Provides for secondary sanctions against foreign financial institutions that have knowingly conducted or facilitated significant financial transactions on behalf of any person sanctioned pursuant to E.O. 13224;
  • Authorizes Treasury to prohibit a foreign financial institution that has knowingly conducted or facilitated a significant transaction with any Specially Designated Global Terrorist (SDGT) from opening or maintaining a correspondent or payable-through account in the United States;
  • Consolidates U.S. counterterrorism authorities under a single sanctions program by eliminating E.O. 12947 and combining that authority’s goal of defending the Middle East Peace Process with E.O. 13224’s global remit and expanded authorities.

For further information on the new Executive Order, OFAC's designations of individuals and entities, and changes to existing SDN listings, see BankersOnline's OFAC Update.

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