Executive Orders are a way for the US President to issue federal directives that set policy or assign work to federal departments and agencies, without the need for legislative approval. Executive Orders are grounded in constitutional and congressional law and give US Presidents broad authority to use their discretion on how to use the resources of the executive branch.
Executive Orders remain in force until they are canceled, revoked, adjusted or expire. The President that issued the Executive Order can change it, as can the next President.
Most, but not all US sanctions, are grounded in executive orders, and require the Departments of State, Treasury and Justice to work together. For example, EO 13224, written as a direct response to the 9/11 attacks and published on 24 September 2001, states that:
- The Secretary of State, in consultation with the Secretary of the Treasury and the Attorney General, may designate foreign individuals or entities that he determines have committed, or pose a significant risk of committing, acts of terrorism that threaten the security of U.S. nationals or the national security, foreign policy, or economy of the U.S.;
- The Secretary of the Treasury, in consultation with the Secretary of State and the Attorney General, may designate individuals or entities that are determined [...]
The reason for this structure is that while sanctions are financial tools, the decision to impose sanctions is a political one, and US sanctions almost exclusively target foreign parties. Hence, sanctions generally start with decisions by foreign policy officials at the White House and Department of State, Treasury then takes the policy directions, identifies targets, financial networks and imposes the sanctions, and Department of Justice reviews the sanctions for accuracy and if they pass muster, is then on the hook to defend the sanctions in court.