Executive Order 13849: Authorizing the Implementation of Certain Sanctions Set Forth in the Countering America's Adversaries Through Sanctions Act

President: Donald J. Trump

Delegated implementation of certain sanctions selected under the Countering America's Adversaries Through Sanctions Act to Treasury and State. The order did not itself establish that every listed sanction had been imposed on a named person.

Status: In effect. Sources: Official source · Official source · Official source.

Is Executive Order 13849 still in effect? Yes. Executive Order 13849 of September 20, 2018 remains an operative CAATSA sanctions authority. OFAC continues to list it among Ukraine- and Russia-related sanctions authorities, and the Federal Register links it to the national-emergency continuation of February 18, 2026.

What does Executive Order 13849 do?

EO 13849 assigned implementation and waiver authorities under CAATSA to the Secretary of State and Treasury, coordinating the executive branch’s sanctions process. It did not itself designate a new person or entity.

Later evidence reviewed September 24, 2026: The State Department updated its CAATSA Section 231 list of Russian defense and intelligence entities under the statutory sanctions framework that EO 13849 helps implement. The list update does not alone identify a separate sanction on every listed entity. State Department CAATSA Section 231 implementation.

Administration position: The stated directions and policy are summarized from the signed order. See the official text for its precise legal terms.
SignedSeptember 20, 2018
IssuerPresident Donald J. Trump
TermFirst presidential term

Before and after

Before the order

The statute prescribed sanctions, while executive implementation and waiver responsibilities needed assignment.

After the order

The State Department updated its CAATSA Section 231 list of Russian defense and intelligence entities under the statutory sanctions framework that EO 13849 helps implement. The list update does not alone identify a separate sanction on every listed entity.

Who had to do what

Agency / officialWhat the signed order directedDeadline / timing
Secretary of the TreasuryWith State consultation, implement selected CAATSA/UFSA financial sanctions: lending limits, foreign-exchange and payment prohibitions, asset blocking, investment/debt restrictions, and selected executive-officer sanctions. May issue implementing rules and redelegate functions.When covered sanctions have been selected; lending sanction covers more than $10 million in 12 months, with the stated humanitarian exception
Secretary of StateConsult on financial and other sanctions; deny visas when selected travel sanctions apply, including covered corporate officers, principals, controlling shareholders, or UFSA-sanctioned persons.Upon the relevant sanction selection/determination
Secretary of Homeland SecurityExclude aliens covered by selected travel sanctions.Upon the relevant sanction selection/determination
Export-Import BankDeny guarantees, insurance, or credit supporting exports to sanctioned persons when that sanction is selected.Upon the relevant sanction selection
US executive director of each international financial institutionUse the US voice and vote to oppose loans benefiting sanctioned persons when that sanction is selected.Upon the relevant sanction selection
Federal Reserve Board of GovernorsBar or discontinue sanctioned financial institutions as primary dealers when that sanction is selected.Upon the relevant sanction selection
Federal Reserve Bank of New YorkBar or discontinue sanctioned financial institutions as primary dealers when that sanction is selected.Upon the relevant sanction selection
Relevant department and agency headsImplement selected export-licensing, procurement, government-agent/depository, defense-export, license-suspension, and executive-officer sanctions with State/Treasury consultation; all agencies must take appropriate implementation measures within their authority.Upon applicable sanction selection; statutes and authorized licenses/exceptions apply

Source: Signed Federal Register text.

What happened next

EO 13849 signed; its Federal Register publication followed.

The State Department updated its CAATSA Section 231 list of Russian defense and intelligence entities under the statutory sanctions framework that EO 13849 helps implement. The list update does not alone identify a separate sanction on every listed entity.