Executive Order 12938 was established by President Clinton to address the unique and exigent threat posed by proliferation of Weapons of Mass Destruction (WMD) and the associated chemical, biological, radiological, and nuclear (CBRN) materials, technologies, expertise, and delivery systems. Section four of the order highlights sanctions which can be levied against foreign persons. Within this section the authority to levy or remove sanctions against foreign persons rests with the Secretary of State. Sanctions against foreign persons can be brought to bear if the entity, “knowingly and materially contributed to the efforts of any foreign country, project, or entity to use, develop, produce, stockpile, or otherwise acquire chemical or biological…