What it captures
Actions establishing or amending the US counter-terrorism sanctions regulatory framework under Executive Orders 13224 and 13886 (31 CFR Part 594), and major operative designation actions under this authority. The perimeter covers global terrorist financiers, FTO supporters, and persons posing a significant risk of committing acts of terrorism against US nationals or national security.
Why it's a distinct theme
Counter-terrorism sanctions are structurally distinct from country-program sanctions (Iran, Russia, Cuba, Sudan) and from the narcotics/narco-trafficking perimeter (EO 14059). The GTSR perimeter is geographically unconstrained and anchored to the State Department FTO list rather than to a national-emergency determination against a specific country — which means OFAC's designation authority follows FTO affiliations globally regardless of the designee's nationality or jurisdiction.
EO 13886's 2019 expansion (FTO-support nexus) was a significant structural change: prior to EO 13886, OFAC could only reach GTSR-adjacent actors with a direct link to an already-blocked SDN; EO 13886 created a direct path from the State FTO list to OFAC designations, closing a gap exploited by third-country fundraising networks for Hamas, Hezbollah, and ISIS affiliates.
Pattern to watch
- Post-October 2023 GTSR enforcement actions against Hamas fundraising networks
in the Gulf, Southeast Asia, and cryptocurrency platforms.
- Whether the FTO-support nexus is used to designate technology intermediaries
(social-media platforms, payment processors) that fail to block FTO-affiliated accounts, following the OFAC precedent in the cryptocurrency space.