In this Special Analysis Edition of The Federal Daily, we examine the Supreme Court’s February 20, 2026 decision holding that the International Emergency Economic Powers Act does not authorize the President to impose tariffs.

This episode moves beyond the daily authority audit format to provide a structured review of the Court’s reasoning, including the role of the major questions doctrine, the constitutional allocation of taxing power, and the division between executive flexibility and legislative authority.

We also discuss the administrative and business implications of the ruling, including the mechanics and uncertainty surrounding potential tariff refunds, and assess alternative statutory pathways such as Sections 232, 301, and 122.

The decision narrows one asserted lane of executive trade authority while reinforcing the Court’s demand for clear congressional delegation in matters of major economic consequence.

The day’s federal activity centered on a Supreme Court ruling redefining executive trade authority and the Treasury’s articulation of economic policy priorities.

The United States Supreme Court held that the International Emergency Economic Powers Act does not authorize the President to impose tariff duties. In a majority opinion, the Court clarified the statutory limits of executive authority under IEEPA, vacated one lower court proceeding for lack of jurisdiction, and upheld another related ruling. The decision constrains presidential discretion over tariff measures and shifts structural leverage over trade policy back toward Congress.

The Treasury Secretary delivered remarks before the Economic Club of Dallas outlining departmental priorities related to economic security, illicit finance, market resilience, and emerging technologies. While not a binding regulatory action, the speech signals Treasury’s supervisory and enforcement posture, shaping interagency coordination and compliance expectations within the financial sector.

Executive branch regulatory and enforcement actions drove institutional authority movement, with shifts concentrated in financial supervision and sanctions execution.

Sudan Sanctions Designations
The Department of the Treasury designated Sudanese paramilitary commanders under existing sanctions authorities. The action imposes binding financial restrictions and reallocates enforcement leverage to the executive branch in response to documented atrocities, directly affecting transaction prohibitions and compliance obligations.

OCC Appeals Rule Proposal
The Office of the Comptroller of the Currency advanced a notice of proposed rulemaking to modify the bank supervisory appeals process. The proposal would alter procedural pathways available to regulated institutions challenging supervisory determinations, affecting administrative review structure within federal banking oversight.

Federal Reserve Regulatory Review
The Federal Reserve approved a banking application and announced a hybrid outreach meeting as part of its regulatory review under the Economic Growth and Regulatory Paperwork Reduction Act. The approval confers operational authority to the applicant institution, while the review process signals potential recalibration of supervisory frameworks and regulatory burden across the banking sector.