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Presidential Memorandum

Delegation of Authority Under Section 8335 of the National Defense Authorization Act for Fiscal Year 2026

Defense & SecurityDefense & SecurityDemocracy & GovernanceDemocracy & Governance

In simple terms

This memorandum delegates presidential authorities under Section 8335 of the FY2026 NDAA to the Secretary of the Treasury and Secretary of State for imposing sanctions on foreign persons involved in certain activities (likely related to foreign interference, based on the cited U.S.C. placement at 22 U.S.C. 10704). The Treasury Secretary receives primary delegation for most sanction functions, with State Department consultation or implementation roles.

Federal Register Open PDF 91 FR 69203

Record & deadlines

  1. Signed

    Signed by the President

  2. FR published

    Published in the Federal Register · 91 FR 69203

    Federal Register PDF

Key directives

  • Delegate to Secretary of Treasury, in consultation with Secretary of State, functions under section 8335(a) of FY2026 NDAA
  • Delegate to heads of relevant executive departments and agencies authority to implement sanctions once foreign persons identified by Secretary of State
  • Delegate to Secretary of Treasury functions under sections 8335(c)(1), 8335(d)(1), 8335(f), and 8335(i)
  • Delegate to Secretary of State functions under section 8335(g)
  • Apply delegations to future substantially similar provisions
  • Secretary of Treasury to publish memorandum in Federal Register

Who is ordered

What to expect

Immediate

  • Delegation of authorities takes effect upon signature
  • Treasury Secretary authorized to publish in Federal Register

Near term (90d)

  • State Department identification of sanctionable foreign persons
  • Agency heads implementing sanctions within their jurisdictions

Long term

  • Ongoing sanctions administration under delegated authorities
  • Application to future substantially similar legislation per Section 2

Risks & tensions

  • Interagency coordination risk between Treasury and State on sanctions designations
  • Vague scope of 'relevant executive departments and agencies' could create implementation gaps
  • Substantially similar provision clause (Sec. 2) creates automatic delegation expansion without further presidential action
Presidential Memorandum: Delegation of Authority Under Section 8335 of the National Defense Authorization Act for Fiscal Year 2026 · Executive Orders