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 determined to be owned or controlled by, or acting for or on behalf of, designated individuals and entities. In its most recent major application, OFAC designated Iran's Persian Gulf Strait Authority (PGSA) under E.O. 13224 on 28 May 2026, part of Treasury's "Economic Fury" campaign, simultaneously with a tentative 60-day memorandum of understanding to reopen the Strait of Hormuz; the legal collision means any vessel using a reopened strait coordinated by the sanctioned PGSA would be transacting with a designated counterparty.

In the broader 2026 Iran conflict, E.O. 13224 is routinely cited alongside E.O. 13902 in OFAC enforcement actions. On 1 May 2026, OFAC invoked both orders in its General Licence W package, designating Bonyad Mostazafan and the tanker NEW FUSION as prohibited channels for Hormuz toll payments. On 15 May 2026, twelve individuals and entities including three IRGC officials and nine Shell companies were designated under the order for routing IRGC oil sales into China. The dual-order citation is standard OFAC practice: stacking post-9/11 terrorism-sanctions authority with Iran-specific executive orders maximises the legal basis and complicates legal challenges.

E.O. 13224 designations are hard to unwind because the order rests on terrorism authority, not oil or nuclear sanctions, which means de-listing requires a finding that the designated entity no longer poses a terrorism-related threat, a higher bar than lifting a trade restriction. The IRGC's 2019 designation under the order as a terrorist organisation was a structural expansion that enabled OFAC to reach IRGC-affiliated entities such as Bonyad Mostazafan via the aiding-and-abetting provisions. For the PGSA designation, unless OFAC issues a specific general licence or de-lists the body, the reopened-Hormuz commercial terms remain legally unworkable from the first vessel transit.