The President on September 10, 2019, authorized the Treasury Secretary to impose sanctions on non-U.S. financial institutions that have knowingly conducted or facilitated a “significant” transaction with anyone sanctioned by the United States as a specially designated global terrorist (SDGT). The new executive order amended Executive Order 13224, which has been the cornerstone of U.S. counter-terrorist financing efforts since 2001.The new executive order increases direct and indirect sanctions risk for non-U.S. financial institutions at the same time that the geographic reach of the U.S. counterterrorism sanctions program is expanding.