Shortly after taking the oath of office today, newly inaugurated President Trump signed a flurry of Executive Orders (“EOs”) and other executive actions. This include several actions related to US sanctions and export controls.
Authority to Designate Cartels as Foreign Terrorist Organizations or Specially Designated Global Terrorists
Trump signed an EO Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists. This EO creates a legal authority to designate certain international cartels as Foreign Terrorist Organizations (“FTOs”) or Specially Designated Global Terrorists, with a focus on cartels in Mexico. Such cartels would be added to the US Treasury Department’s Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List (“SDN List”) which, if they are not already on the SDN List under another sanctions program, essentially cuts them off from the US market and makes cross-border transactions more difficult. Further, it is a crime to provide “material support or resources” to an FTO.
Rescinded Biden Actions on Cuba, the International Criminal Court, and West Bank
President Trump signed an omnibus EO rescinding the following sanctions-related EOs and executive actions. Stay tuned for a more detailed blog post on the Cuba sanctions developments.
| Topic | Action | Description |
| Cuba | Rescinded the Presidential Memorandum of January 14, 2025 (Certification of Rescission of Cuba’s Designation as a State Sponsor of Terrorism), Rescinded the Presidential Memorandum of January 14, 2025 (Revocation of National Security Presidential Memorandum 5): | President Biden had rescinded Cuba’s designation as a State Sponsor of Terrorism just days ago and relaxed certain sanctions. Cuba is now back on the List of State Sponsors of Terrorism, and the limited sanctions relaxation has been reversed. |
| International Criminal Court | Rescinded EO 14022 of April 1, 2021 (Termination of Emergency With Respect to the International Criminal Court) | President Biden signed EO 14022 to revoke EO 13928 of June 11, 2020, which President Trump signed in his first Administration to authorize the imposition of sanctions against persons associated with the International Criminal Court. See our prior blog post on EOs 14022 and 13928 here. Such persons are once again at risk of being sanctioned. |
| West Bank | Rescinded EO 14115 of February 1, 2024 (Imposing Certain Sanctions on Persons Undermining Peace, Security, and Stability in the West Bank) | President Biden signed EO 14115 to authorize sanctions against persons determined by the US Government to be involved in activities threatening the peace, security, and stability of the West Bank. See our prior blog post on EO 14115 here. The immediate effect is to remove the sanctions that were imposed on several parties under EO 14115, and to eliminate the risk of future sanctions on this basis. |
America First Trade Policy
Most of the America First Trade Policy issued today focuses on tariffs, import duties, and trade agreements – see our sister blog, Import and Trade Remedies Blog, for more on developments in that space. The policy also contains a provision directing the Secretaries of State and Commerce to review and assess the US “export control system,” make recommendations to support the US’s technological edge, eliminate loopholes, assess enforcement practices, and incentivize compliance by foreign countries.
