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Presidential Memorandum

Delegation of Certain Sanctions-Related Authorities Under Public Law 118-50

This memorandum delegates presidential sanctions authorities under multiple acts within Public Law 118-50 to specific Cabinet secretaries. It assigns implementation responsibilities for Iran-related petroleum sanctions, missile export controls, human rights accountability, terrorist group financing prevention, technology export controls, human shields countermeasures, Captagon trafficking suppression, and Iranian leadership accountability to the Secretaries of Treasury, State, Defense, Commerce, and the Attorney General, often requiring interagency consultation.

Federal Register Open PDF 89 FR 77757

Impact dates

  1. Federal Register filing (actual filing date shown in document header)

Key directives

  • Delegate SHIP Act sections 3(a), 3(c)(1), 3(e) to Treasury (consulting State)
  • Delegate SHIP Act section 3(c)(2) to Treasury
  • Delegate SHIP Act sections 3(h), 3(i) to State
  • Delegate Fight CRIME Act sections 5(a)(1)-(4) to State (consulting Treasury)
  • Delegate Fight CRIME Act sections 5(a)(5), 5(a)(6), 5(e), 5(f) to Treasury (consulting State)
  • Delegate Fight CRIME Act section 5(b)(1) to Treasury
  • Delegate Fight CRIME Act sections 5(d), 5(h), 6(c) to State
  • Delegate MAHSA Act sanctions authorities to Treasury and State with specified consultations
  • Delegate Terrorist Groups International Financing Prevention Act authorities to State, Treasury, Commerce, Defense with specified consultations
  • Direct Commerce to consult State and Treasury under No Technology for Terror Act
  • Delegate Countering Use of Human Shields Act authorities to Treasury, State, Attorney General with consultations
  • Delegate Captagon Suppression Act authorities to Treasury and State

Who is ordered

Timeline

Immediate

  • Delegation of authorities takes effect upon signing
  • Secretaries assume designated sanctions implementation roles

Near term (90d)

  • Federal Register publication by Secretary of State (filed 9-23-24)
  • Interagency consultation mechanisms must become operational

Long term

  • Ongoing sanctions enforcement under delegated authorities
  • Potential sanctions designations and regulatory actions by Treasury and State

Risks & tensions

  • Complex interagency consultation requirements may slow enforcement
  • Overlapping Treasury-State jurisdictions could create coordination friction
  • No explicit reporting deadlines or metrics for implementation
  • Document does not specify whether prior delegations were revoked or superseded
Presidential Memorandum: Delegation of Certain Sanctions-Related Authorities Under Public Law 118-50 · Executive Orders