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Recent court rulings enjoining enforcement of the Trump Administration’s Executive Order (“EO”) targeting TikTok show signs of curbing the sweeping powers of the International Emergency Economic Powers Act (“IEEPA”), which arguably sits at the center of the modern U.S. sanctions and export control regimes. Separate statutory constraints with respect to restrictions on sales of agricultural commodities, food, medicine, and medical supplies could also potentially limit the impact of the designation of the Xinjiang Production and Construction Corps (“XPCC”).
While Presidents have often turned to IEEPA to impose economic sanctions in furtherance of U.S. foreign policy and national security objectives, the Trump administration’s reliance on IEEPA authority for its TikTok EO appears to be having a rough time getting past the courts. Similarly, the impact of the Trump Administration’s designation of XPCC as a S