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A Primer on Anti-Terrorism Requirements in Leasing Transactions: Complying with Executive Order 13224

By David A. Grossberg, Melissa J. Krasnow and Randolph M. Perkins

Shortly after September 11, 2001, President Bush issued Executive Order 13224 (the “Order”) to combat terrorism. The title of the Order, “Blocking Property and Prohibiting Transactions with Persons who Commit, Threaten to Commit, or Support Terrorism” aptly describes the protective measures contemplated by the Order. Among other things, the Order applies to all real estate transactions, including commercial leases. All owners, tenants, guarantors and other parties to lease transactions, as well as their respective agents and affiliates, are obliged to comply with this Order. Given the critically important national interest at stake, as well as the stern penalties that can be encountered for noncompliance, it is essential for all parties involved in real estate transactions to be aware of the Order's requirements and to include compliance measures in all dealings.

Goals and Implementation of the Order

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