NDAA Update Oct 31, 2026: President Delegates NDAA Sanctions Authority to Treasury and State

President Delegates NDAA Sanctions Authority to Treasury and State

Daily Federal · Oct 31, 2026

Daily Federal reports that on October 28, 2026, the President issued a memorandum titled "Delegation of Authority Under Section 8335 of the National Defense Authorization Act for Fiscal Year 2026," assigning sections of the enacted FY2026 NDAA — not the pending FY2027 bill — to the Treasury and State secretaries and to agency heads. The memorandum delegates 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) (22 U.S.C. 10704(a)); once sanctionable foreign persons are identified by the Secretary of State, heads of relevant executive departments and agencies may implement such sanctions. The President further delegated to Treasury the authorities under sections 8335(c)(1) and 8335(d)(1), section 8335(f) in consultation with the Secretary of State, and 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. Section 3 directs the Secretary of the Treasury to publish the memorandum in the Federal Register. The notice appears as FR Doc. 2026-22386, 91 FR 69203 (Federal Register Volume 91, No. 210, pages 69203-69204), filed on October 30, 2026 at 11:15 a.m., on public inspection October 30 and publishing November 2.