President Delegates NDAA Sanctions Authority to Treasury and State
The memorandum, dated Oct. 28 2026, assigns sections of the FY-2026 National Defense Authorization Act to the Treasury and State secretaries and to agency heads.
On October 28, 2026, the President issued a memorandum delegating to the Secretary of the Treasury, in consultation with the Secretary of State, the functions and authorities vested in the President by section 8335(a) of the National Defense Authorization Act for Fiscal Year 2026 (22 U.S.C. 10704(a)). The delegation also extends to heads of relevant executive departments and agencies, enabling them to implement sanctions once sanctionable foreign persons are identified by the Secretary of State.
The President further delegated to the Treasury the authorities under sections 8335(c)(1) and 8335(d)(1), as well as the authority under section 8335(f) in consultation with the Secretary of State, and the authority under section 8335(i). The Secretary of State received the authority vested in the President by section 8335(g).
Section 2 of the memorandum provides that these delegations apply to any provision of any future public law that is the same or substantially the same as the referenced provision, and that references to the Act are deemed to include any amendments.
Section 3 directs the Secretary of the Treasury to publish the memorandum in the Federal Register. The notice appears in Federal Register Volume 91, No. 210, pages 69203-69204, FR Doc No. 2026-22386, filed on October 30, 2026 at 11:15 a.m.
Further reading