Today, the President issued a new Executive Order (E.O.) “Modernizing Sanctions to Combat Terrorism.” This 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 amended E.O. strengthens and expands both the Department of State’s and the Treasury’s authorities to target terrorists and their supporters, including by imposing correspondent account or payable-through account sanctions on any foreign financial institution that knowingly conducted or facilitated any significant transaction for or on behalf of any Specially Designated Global Terrorist after the effective date.
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