On November 27, 2018, President Trump signed Executive Order 13851, authorizing the Treasury Department to identify, designate, and freeze the property and assets of individuals and entities determined to be contributing to the political and humanitarian crisis in Nicaragua. The order granted broad discretionary power to the Treasury's Office of Foreign Assets Control (OFAC) to compile lists of targeted persons without requiring congressional approval or judicial review before asset seizures took effect. Any American citizen or entity conducting financial transactions with designated individuals—whether through direct business dealings, banking relationships, or investment holdings—faced automatic asset freezes and transaction prohibitions.

The order directly affected U.S. persons with financial exposure to Nicaragua, including American business owners with operations there, investors holding shares in Nicaraguan companies, financial institutions processing transactions involving designated parties, and American citizens maintaining bank accounts or property jointly with affected individuals. OFAC's designation authority operated with minimal transparency; individuals and entities could be added to sanctions lists with limited opportunity to challenge designations before their assets were immobilized.

This action reflects a broader pattern of unilateral executive action in foreign policy that prioritizes rapid enforcement over institutional checks. Similar to the visa restrictions imposed on Sinaloa Cartel associates and the continuation of Iran emergency authorities, Executive Order 13851 concentrated power in the executive branch to impose economic penalties without standard congressional oversight. The Nicaragua sanctions joined a growing constellation of OFAC designations affecting American financial activity abroad, creating a complex compliance burden for businesses and individuals navigating international transactions.

No significant court challenges directly invalidated the order's core mechanisms, though OFAC designations generally remain subject to administrative appeal and potential legal challenge on constitutional grounds. The executive authority to block property in response to foreign policy crises has withstood judicial scrutiny under the International Emergency Economic Powers Act framework, though individual designations have sometimes been successfully contested as lacking sufficient evidentiary basis.