E.O. 13224

Executive Order 13224, signed by President George W. Bush on 23 September 2001 — twelve days after the 11 September attacks — blocks the property and interests in property of foreign persons who commit, threaten to commit, or support acts of terrorism. It also extends blocking authority to persons who are determined to be owned or controlled by, or acting for or on behalf of, designated individuals and entities. The order remains the foundational US counterterrorism sanctions instrument and has been used continuously for over two decades.

In the 2026 Iran conflict, E.O. 13224 is regularly cited alongside E.O. 13902 in OFAC enforcement actions. On 1 May 2026, OFAC invoked both orders simultaneously in its General Licence W package, designating Bonyad Mostazafan and the tanker NEW FUSION as prohibited channels for Hormuz toll payments. The dual citation is standard OFAC practice: stacking post-9/11 terrorism-sanctions authority with Iran-specific executive orders maximises the legal basis for designation and complicates legal challenges.

The IRGC was designated under E.O. 13224 as a terrorist organisation in 2019, enabling OFAC to reach IRGC-affiliated entities such as Bonyad Mostazafan under the order's aiding-and-abetting provisions. This layered approach means that an entity need not itself engage in terrorism to be reached; mere financial support to a designated entity is sufficient.