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Key Figures

President Joe Biden used a January 17, 2025 memorandum to delegate several sanctions-related presidential powers to cabinet officials. The memo assigned FEND Off Fentanyl Act authorities to the Treasury secretary, the secretary of state, the attorney general, the commerce secretary, and the homeland security secretary, depending on the provision. It also delegated authorities tied to Division G of Public Law 118-50 and the Iran-China Energy Sanctions Act of 2023. The action mattered because Congress had given the president formal sanctions powers, but federal agencies needed delegated authority to turn those powers into enforcement decisions, financial restrictions, and other sanctions actions.

President Joe Biden signed a January 3, 2025 executive order setting who could act as attorney general if the attorney general, deputy attorney general, associate attorney general, and officials designated under 28 U.S.C. 508 were unable to serve. The order placed the U.S. attorney for the Southern District of New York first, followed by U.S. attorneys for the District of Arizona, Northern District of Illinois, and District of Hawaii. It relied on the Federal Vacancies Reform Act and revoked President Donald Trump’s 2017 Justice Department succession order. The action mattered because the attorney general leads federal law enforcement, civil-rights enforcement, criminal prosecution policy, and legal representation for the United States.