Trump Sanctions Policies Still Undefined, But Could Affect Many Nations and Compliance Officers – Part 3: Steven Bannon’s “America First” Agenda Looms As Big Factor

January 31, 2017
By: Anna Sayre, Legal Content Writer,

In this series, we present the comments and assertions made by President Donald Trump and his top assistants concerning economic sanctions and export controls so compliance professionals can make informed decisions as to the likely positions of the new U.S.administration in the next four years.

In this third part, we present the views of Chief White House Strategist, Steven Bannon, the former president of Breitbart News, a nationalist, extreme rightist broadcasting operation.

US Chief Strategist and National Security Council

Unlike other traditional White House positions, such as Chief of Staff, the role of ‘Chief Strategist’ is relatively new and, therefore, yet to be properly defined. Only recently has this new position begun to take shape.

By executive order of January 28, 2017, Trump created a permanent seat for Bannon on the White House National Security Council (NSC).

The advisory council, established in 1947, is normally responsible for discussing and advising the White House on national security issues and foreign policy. In other words, the NSC ensures that the President has the best possible advice from his Cabinet, as well as the top military and the intelligence community before making important decisions that may affect the country.

The order has also limited the roles of the Director of National Intelligence and Chairman of the Joint Chiefs of Staff – two of the highest ranking US intelligence and military officials – who will now only attend NSC meetings when “issues pertaining to their responsibilities and expertise are to be discussed”.

“I don’t believe there is any legally mandated level of influence for any particular advisor in the White House, however, the White House in certain cases either sets sanctions policy directly or indirectly. As part of that role, advisors in the White House are involved and have influence in the process. Bannon is trusted by the President and has the President’s ear on wide variety of issues” says Erich Ferrari, Founder and Principal of Ferrari & Associates, P.C. in Washington D.C.

In Bannon’s words in an interview in August 2016, referring to the famous influential advisor to England’s King Henry VIII, “I am Thomas Cromwell in the court of the Tudors.”

Unfettered Access

As the U.S. President, Trump can impose or lift sanctions by the exercise of Presidential national emergency powers through executive orders. The International Emergency Economic Powers Act (IEEPA) grants the President broad authority to respond to “unusual or extraordinary threat[s]” to the national security, foreign policy, or US economy.  The President exercises this authority by officially declaring what he/she believes to be a ‘national emergency’.

As Chief Strategist, and now a member of the NSC, Bannon will have unfettered access to President Trump.

Bannon is private and does not normally give interviews or speeches. On the rare occasions when he speaks out or conducts a radio interview on “Breitbart News Daily”, he provides insight into how he hopes to shape U.S. policy.


On July 12, 2016, Bannon interviewed Robert Spencer, director of anti-Muslim website Jihad Watch, about Spencer’s book The Complete Infidel’s Guide to Iran. Bannon and Spencer discussed Iran and the nuclear deal or Joint Comprehensive Plan of Action (JCPOA) brokered by President Obama.

Bannon said, “[Iran is] so out front – by saying they are our mortal enemy, they are going to destroy us, it’s in everything they talk about, they don’t try to hide it – why do we seem as a country and a nation, incapable of accepting that and addressing it?” Bannon asked about the JCPOA, “What was the internal logic of cutting the Iran deal?”Spencer explained that the Obama administration and Congress seem to believe the JCPOA will act as an “olive branch” that will bring peace and stability to the region. Bannon asked, “is there any pattern of evidence in the history of Persia or the history of Iran since it has become Islamic to show that showing them an olive branch has even worked? Spencer said, “Never…Not one bit”.

Economic Ties With China

 Currently, the U.S. has no sanctions against China, but maintains certain export controls to regulate trade and prevent proliferation of weapons of mass destruction. Generally, the U.S. enjoys open trade relations with China, which were bolstered by the Obama administration.

Bannon is skeptical of most international alliances and favors imposing hard line trade restrictions in order to return industry and manufacturing to the U.S. In a speech on October 25, 2011 to the Liberty Restoration Foundation in Orlando, Bannon spelled out his thoughts on trade with China: “The biggest problem we have that never gets talked about at any debate, has not been brought up one time: the trade deficit – which every quarter, all the goods we buy from China, all the foreign oil we buy – is $7 trillion. It is the beating heart of our problem.”

US Sanctions Against Russia

 U.S. sanctions on Russia were imposed after it annexed Crimea in 2014,supports separatist movements in Ukraine, and undermines Ukraine’s democracy and territorial integrity. As it stands, there is no congressional approval needed to lift the US sanctions on Russia, thus allowing the President much discretion.President Trump could simply lift sanctions on Russia by Executive Order.

Bannon revealed his views on Russia and President Putin in remarks by Skype to the Dignitatas Humanae Institute conference at the Vatican in the summer of 2014.

“I am not justifying Vladimir Putin and the kleptocracy that he represents (…). I think that Putin and his cronies are really a kleptocracy, an imperialist power that wants to expand. However, I really believe that in this current environment, where you’re facing a potential new caliphate that is very aggressive, that is really a situation. I’m not saying we can put it on a back burner — but I think we have to deal with first things first,” said Bannon.

Unlike Trump, who according to a November 14, 2016 article in the Washington Post, “appears to absolve Russia from responsibility for intervention in Ukraine and annexation of Crimea,” Bannon’s comments do not appear to approve Russia’s expansion into Crimea.However,Bannon places priority on fighting the Islamic State, as does Trump, leaving the door open for cooperation with Russia–and therefore potential sanctions relief- in the effort against the militant group.


 On December 17, 2014, President Obama made a historic speech that set off a course of diplomatic and economic changes charting a new course in U.S. relations with Cuba. Since then, several restrictions on travel, banking, trade and communications with Cuba have been lifted, although the general US embargo on Cuba remains.

Bannonh as remained mainly silent about his stance on Cuba.However,articles posted on Breitbart News provide clues to his views. An article, “Top 10 lies in Obama’s Cuba Speech”, written by Joel Pollak, senior Breitbart editor-at-large, posted December 18, 2014, the day after Obama’s speech, stated that despite Obama’s assurances that Cuba renounces terrorism, “Cuba was caught only last year, smuggling ’missile equipment’ to North Korea” and “continues to offer other kinds of support to terrorists”.

What this means for future of U.S. sanctions on Cuba in a Trump administration remains an open question.

In another part of this series, Mr. Trump’s comments and assertions concerning Cuba will be analyzed.

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