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MemoMemorandumObama · D Quiet signal

Presidential Memorandum

Delegation of Certain Functions and Authorities Under the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010

This memorandum delegates specific presidential authorities under the Iran Sanctions Act of 1996 (as amended by CISADA) and CISADA itself to the Secretary of State, Secretary of the Treasury, Secretary of Commerce, Attorney General, U.S. Trade Representative, Federal Reserve Chairman, and Export-Import Bank President. It maintains a prior 1996 memorandum for certain provisions while reassigning others.

Federal Register Open PDF 75 FR 67025

Impact dates

  1. Federal Register publication by Secretary of State

Key directives

  • Delegate Iran Sanctions Act sections 4(c), 5(a)-(c), 5(f), 6(a)(1)-(2), 6(b)(5), 9(c) to Secretary of State with multi-agency consultation
  • Delegate Iran Sanctions Act sections 4(a)-(b), 4(e), 5(d)-(e), 9(a)-(b), 10 to Secretary of State
  • Delegate conditional Iran Sanctions Act sections 6(a)(6)-(8) to Secretary of Treasury with State consultation
  • Delegate CISADA section 102(h)(5) to Secretary of State
  • Delegate CISADA section 103(b)(3) to Secretary of State and Secretary of Treasury consistent with EO 13224 and EO 13382
  • Delegate CISADA section 103(d)(1)-(2) to Secretary of Treasury with State consultation
  • Delegate CISADA section 103(d)(2)(B) to Secretary of State with Treasury and Commerce consultation
  • Delegate CISADA section 106 to Secretary of State with Commerce consultation
  • Delegate CISADA section 110 to Secretary of State
  • Delegate CISADA section 111(a) to Secretary of State with Treasury and Ex-Im Bank consultation
  • Delegate CISADA section 111(b) to Ex-Im Bank President with State and Treasury consultation
  • Delegate CISADA section 115 to Secretary of State with Attorney General and Treasury consultation

Who is ordered

Timeline

Immediate

  • Delegation of functions takes effect upon signing
  • Prior 1996 memorandum remains in effect for section 102(h)(2) implementation

Near term (90d)

  • Federal Register publication by Secretary of State

Long term

  • Ongoing implementation of Iran sanctions regime by delegated agencies

Risks & tensions

  • Complex multi-agency consultation requirements may create implementation friction or delays
  • Conditional delegation of 6(a)(6)-(8) to Treasury creates uncertainty about when trigger conditions are met
  • Split jurisdiction over export controls (Commerce for EAR, State for ITAR) requires careful coordination
  • Waiver authorities concentrated in Secretary of State may create tension with Treasury on financial sanctions
Presidential Memorandum: Delegation of Certain Functions and Authorities Under the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 · Executive Orders