President Donald Trump on Wednesday delegated sanctions authorities under Section 8335 of the National Defense Authorization Act for Fiscal Year 2026 to the Department of the Treasury and the Department of State, according to a presidential memorandum.
The memorandum assigns Treasury, in consultation with State, to carry out the functions and authorities vested in the President by Section 8335(a) of the law (22 U.S.C. 10704(a)). It says that once the Secretary of State identifies sanctionable foreign persons, the heads of relevant executive departments and agencies are delegated authority, within their areas of responsibility, to implement the sanctions. The memorandum is addressed to the Secretary of State and the Secretary of the Treasury.
The document further delegates to the Secretary of the Treasury the authorities in Sections 8335(c)(1) and 8335(d)(1). It also delegates to Treasury, in consultation with State, the authorities in Section 8335(f). The Secretary of State is delegated the authorities in Section 8335(g), and the Secretary of the Treasury is delegated the authorities in Section 8335(i), the memorandum says.
The memorandum states that these delegations will also apply to any provision in a future public law that is the same or substantially the same as the provisions referenced. It adds that any reference in the memorandum to any act is deemed to be a reference to that act as it may be amended over time.
The Secretary of the Treasury is authorized and directed to publish the memorandum in the Federal Register. The memorandum was signed Oct. 28, 2026, and is identified as Federal Register Document Number 2026-22386.
The Executive Office of the President published the text in the Federal Register scheduled for Nov. 2, 2026. The document does not state how many departments or agencies will implement sanctions under this delegation beyond those referenced.