On 10 September 2019 the U.S. President issued an Executive Order (E.O.) entitled “Modernizing Sanctions to Combat Terrorism.” This new E.O. amends E.O. 13224 (“Blocking Property and Prohibiting Transactions with Persons Who Commit, Threaten to Commit, or Support Terrorism”) and terminates the national emergency declared in E.O. 12947 (“Prohibiting Transactions with Terrorists Who Threaten to Disrupt the Middle East Peace Process”). The new E.O. expands the authority of the U.S. State and Treasury Departments to target terrorists and their supporters. In addition, under the new E.O., the Treasury Department can sanction correspondent accounts or payable-through accounts of foreign financial institutions who knowingly facilitate transactions with terrorists. Following this new E.O., 28 new individuals and entities have been sanctioned.
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