E.O. 13224
US counterterrorism executive order of 23 September 2001, blocking property of persons supporting terrorism.
E.O. 13224, the 2001 counterterrorism order that lets Treasury reach IRGC-linked entities, was used on 30 July 2026 to designate DadeNegar Startup Studio as part of a Hormuz-insurance sanctions package.
Last refreshed: 17 August 2026 · Appears in 1 active topic
Why does sanctioning Iran's toll body block a Hormuz peace deal?
Timeline for E.O. 13224
Mentioned in: Iran sanctions the register can't find
Iran Conflict 2026Mentioned in: Treasury freezes Iran's four crypto exchanges
Iran Conflict 2026Provided statutory authority for the PGSA designation
Iran Conflict 2026: US sanctions the strait it will reopenOFAC designates twelve for IRGC oil routing
Iran Conflict 2026Mentioned in: Economic Fury hits four Hong Kong shells
Iran Conflict 2026Background
E.O. 13224 is a US executive order President George W. Bush signed on 23 September 2001, twelve days after the September 11 attacks. It blocks the property of foreign persons who commit, threaten or support terrorism, and extends to anyone acting on their behalf.
Its reach into Iran sanctions runs through the Islamic Revolutionary Guard Corps' 2019 designation as a terrorist organisation, which lets Treasury use the order against IRGC-affiliated entities such as Bonyad Mostazafan. That distinguishes it from Executive Order 13902's economic-sector basis and Executive Order 13382's WMD-proliferation basis.
Because de-listing under a terrorism authority requires OFAC to certify an entity no longer poses a terrorism-related threat, designations under E.O. 13224 are harder to reverse than those made under Treasury's other Iran authorities, making it the order Treasury reaches for when it wants a sanction to stick.
Treasury keeps using terrorism authority
OFAC's most recent E.O. 13224 action designated DadeNegar Startup Studio on 30 July 2026, part of a Hormuz-insurance package that named two other firms under the separate E.O. 13902 the same week.
The order underpinned an earlier contradiction on 28 May, when Treasury designated Iran's Persian Gulf Strait Authority the same day a tentative memorandum to reopen the Strait of Hormuz was reached: any vessel using a PGSA-coordinated transit would be transacting with a sanctioned counterparty.
E.O. 13224 targets IRGC oil routing
On 15 May 2026 OFAC used E.O. 13224 to designate twelve entities routing Islamic Revolutionary Guard Corps oil sales into China, including three named IRGC officials. The IRGC's 2019 terrorism designation under the same order is what lets Treasury reach entities operating on its behalf.
De-listing under E.O. 13224 requires OFAC to find an entity no longer poses a terrorism-related threat, a higher bar than removing a trade restriction under E.O. 13902, so any name added under this order is harder to unwind.
What is E.O. 13224 and how does it relate to Iran sanctions?
Why does OFAC cite both E.O. 13224 and E.O. 13902 in Iran sanctions?
When was the IRGC designated under E.O. 13224?
What is Executive Order 13224 and how does it work?
Why did the US sanction Iran's Persian Gulf Strait Authority under EO 13224?
Why is an E.O. 13224 sanction harder to remove than other Iran sanctions?
When was the IRGC designated under Executive Order 13224?
How does Executive Order 13224 affect Hormuz shipping after the PGSA designation?
Why was DadeNegar Startup Studio sanctioned under E.O. 13224?
