On September 8, 2017, the Trump administration issued Determination 2017-19522, formally continuing the exercise of authorities granted under the Trading With the Enemy Act, a 1917 statute that grants the president broad powers to regulate or prohibit transactions with foreign nations and individuals designated as enemies or threats to national security. This determination preserved existing presidential authority to control trade, financial transactions, investment, and communications with specified foreign entities without requiring congressional authorization for each instance.

The practical effect of this continuation extended to numerous categories of individuals and organizations already designated under the act's framework. American businesses engaged in international commerce faced ongoing restrictions on transactions with targeted foreign governments and their associated entities. Financial institutions conducting international transfers encountered regulatory obligations to screen transactions and block those involving sanctioned parties. Citizens and permanent residents with family members or business interests in designated countries experienced limitations on remittances, travel-related financial activities, and commercial dealings. The determination functionally expanded the executive branch's unilateral capacity to control cross-border economic activity.

This determination reflects an escalating pattern of executive control over foreign relations visible throughout the Trump administration's tenure. The continuation of Trading With the Enemy Act authorities provided the legal scaffolding for subsequent actions targeting Iran specifically, as demonstrated in the administration's later directives such as the continuation of the Iran national emergency declaration and Executive Order 14382 addressing Iranian government threats. These actions collectively created a layered enforcement apparatus allowing sweeping restrictions without individual congressional review, a mechanism that extended beyond Iran to justify arms deals to Middle Eastern partners and restrictions on transnational criminal organizations like the Sinaloa Cartel.

The Trading With the Enemy Act determination operates largely outside judicial review mechanisms. Once authorized, such determinations face minimal procedural obstacles, though affected parties may challenge specific applications through administrative or court proceedings. Congressional oversight remains theoretically available but rarely exercised given the broad bipartisan security consensus around such designations.

Reversal would require either a new presidential determination narrowing these authorities or congressional action reasserting its constitutional role in regulating interstate and foreign commerce.