On September 9, 2020, the Trump administration issued a formal determination under the Trading With the Enemy Act, a World War I-era statute that grants the executive branch sweeping powers to restrict commercial and financial transactions during periods of national emergency. The determination, filed as document 2020-20377, extended existing authorities that had been invoked under previous administrations to maintain ongoing trade restrictions and financial controls targeting designated foreign entities and nations. This action did not introduce new restrictions but rather perpetuated existing ones, effectively renewing the executive's ability to regulate which Americans could legally conduct business with specified countries and entities.

The practical effect of this determination fell directly on American businesses, financial institutions, and private citizens attempting to engage in international commerce and financial transactions. Companies seeking to export goods, provide services, or transfer funds to designated nations faced criminal and civil penalties for unauthorized transactions. Individual Americans holding assets, maintaining family businesses, or possessing financial interests in restricted territories encountered complications accessing their own resources. Financial institutions operating under these constraints necessarily denied services to customers with any connections to blacklisted entities, creating cascading restrictions that extended far beyond the original designations.

This 2020 continuation reflects a broader pattern of executive escalation in foreign policy unilateralism that intensified throughout the Trump administration's second term. The determination sat within a constellation of increasingly aggressive restrictions, including the continuation of Iran national emergency declarations, comprehensive Iran-related sanctions orders, and accelerated military deployments to the Middle East. These measures collectively represented an expansion of executive trading and financial authority that circumvented traditional congressional oversight mechanisms for trade and foreign policy decisions.

The Trading With the Enemy Act itself carries significant constitutional questions regarding the delegation of legislative power to executive authorities, though courts have historically upheld its application during recognized emergencies. No major legal challenges to this specific 2020 determination were documented, nor did Congress mount a legislative response to reverse it during the remainder of the administration's term.