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The Global Terrorism Sanctions program has two enabling authorities:
blocking property of persons determined to have committed, or to pose a significant risk of committing, acts of terrorism that threaten the security of US nationals or the national security, foreign policy, or economy of the United States.
1(a) and section 5 of EO 13224. The key additions: OFAC may now designate foreign persons who (i) act for or on behalf of, or are owned or controlled by, any person whose property is blocked under EO 13224; (ii) have committed, or pose a significant risk of committing, acts of terrorism that threaten US nationals or national security, foreign policy, or economy; or (iii) directly or indirectly provide material support, financing, or technological support to a foreign terrorist organization (FTO) as designated by the Secretary of State under the Immigration and Nationality Act.
The third prong — the FTO-support authority — is the substantive addition. Prior to EO 13886, OFAC's GTSR perimeter could only reach persons linked to already-blocked individuals. EO 13886 created a direct nexus to the State Department's FTO designation list (e.g., Hamas, Hezbollah, ISIS, al-Qaeda, Palestinian Islamic Jihad), allowing OFAC to designate material supporters of those organizations without requiring a prior SDN anchor in the GTSR programme.
What the 2022 final rule does: The rule formalises EO 13886 into the regulatory text of 31 CFR Part 594 — updating:
EO 13886 grounds, including the FTO-support nexus.
blocked under the expanded §594.201 criteria.
align internal regulatory citations with the amended authority structure.
Emergency Economic Powers Act (IEEPA), and the National Emergencies Act.
The rule was promulgated as a final rule without notice-and-comment under the foreign affairs exception to the APA (5 U.S.C. 553(a)(1)), consistent with OFAC's standard practice for regulations implementing Executive orders where the underlying authority derives from a presidential determination.
The EO 13886 FTO-support nexus means OFAC's GTSR designation authority now tracks State's FTO list in real time. When State adds an organisation to the FTO list (or designates a new affiliate), OFAC gains contemporaneous authority to designate the FTO's material supporters, financiers, and recruiter networks under GTSR — without needing to first find a linked SDN anchor. This closes a gap where non-state terrorist financiers with no direct personal SDN link could previously transact with US-person counterparties if the transaction didn't touch an already-blocked individual.
In practice the 2022 rule has been used as the basis for subsequent GTSR designations targeting Hamas fundraising networks in third countries (particularly in the Gulf and Southeast Asia) following the October 2023 attacks.
apply GTSR screening not only to persons already listed on the SDN list under GTSR but also to any person whose nexus to an FTO triggers a determination under the expanded §594.201 — a compliance obligation requiring integration of the State FTO list into OFAC screening workflows.
services, and cryptocurrency exchanges that process payments without robust destination-of-funds controls when funds are linked to organisations on the FTO list.
violations enforceable under IEEPA's civil penalty regime (up to USD 1.4 million per violation, inflation-adjusted annually).
support" determinations under the FTO-nexus prong — particularly relevant for small- denomination crowdfunding flows and cryptocurrency transactions where tracing is technically feasible but operationally complex.
charitable organisations with dual civilian/militant-financing profiles in the context of post-October 2023 enforcement.