ABSTRACT
Just thirteen days after the September 2001 attacks and the declaration of a national emergency, then-President Bush signed EO 13224, Blocking Property and Prohibiting Transactions with Persons Who Commit, Threaten to Commit, or Support Terrorism. Attached to the order was a list of easily recognizable terrorist groups but also more obscure financing actors such as charities, trusts, and export companies. Although the intelligence community always suspected that funding to terrorists was coming from these sources, the tragic events of 9/11 and the subsequent unraveling of the money trail officially brought the situation to the table.
