Yes, if the President declared a national emergency related to an unusual or extraordinary foreign threat and identified the NRA as intrinsically linked to foreign interests.
President Trump's actions, in this case, come under authority granted to limit transactions with respect to foreign interests, under 50 U.S.C. 1702(a)(1):
(1) At the times and to the extent specified in section 1701 of this
title, the President may, under such regulations as he may prescribe,
by means of instructions, licenses, or otherwise—
(A) investigate,
regulate, or prohibit—
- (i) any transactions in foreign exchange,
- (ii) transfers of credit or payments between, by, through, or to any
banking institution, to the extent that such transfers or payments
involve any interest of any foreign country or a national thereof,
- (iii) the importing or exporting of currency or securities, by any
person, or with respect to any property, subject to the jurisdiction
of the United States;
(B) investigate, block during the pendency of an
investigation, regulate, direct and compel, nullify, void, prevent or
prohibit, any acquisition, holding, withholding, use, transfer,
withdrawal, transportation, importation or exportation of, or dealing
in, or exercising any right, power, or privilege with respect to, or
transactions involving, any property in which any foreign country or a
national thereof has any interest by any person, or with respect to
any property, subject to the jurisdiction of the United States;
and.
(C) when the United States is engaged in armed hostilities or
has been attacked by a foreign country or foreign nationals,
confiscate any property, subject to the jurisdiction of the United
States, of any foreign person, foreign organization, or foreign
country that he determines has planned, authorized, aided, or engaged
in such hostilities or attacks against the United States; and all
right, title, and interest in any property so confiscated shall vest,
when, as, and upon the terms directed by the President, in such agency
or person as the President may designate from time to time, and upon
such terms and conditions as the President may prescribe, such
interest or property shall be held, used, administered, liquidated,
sold, or otherwise dealt with in the interest of and for the benefit
of the United States, and such designated agency or person may perform
any and all acts incident to the accomplishment or furtherance of
these purposes.
Additionally, we see in 50 U.S.C. 1701 that:
Any authority granted to the President by section 1702 of this title
may be exercised to deal with any unusual and extraordinary threat,
which has its source in whole or substantial part outside the United
States, to the national security, foreign policy, or economy of the
United States, if the President declares a national emergency with
respect to such threat.
So the first requirement would be for the President to declare a national emergency under these terms. In the case of TikTok, this was declared on May 15th, 2019 - Executive Order on Securing the Information and Communications Technology and Services Supply Chain.
Secondly, the President would only be able to prohibit transactions involving the NRA related to foreign interests. In this case, the transactions prohibited were those related to TikTok's current owner, the Chinese company ByteDance Ltd.
any transaction by any person, or with respect to any property,
subject to the jurisdiction of the United States, with ByteDance Ltd.
(a.k.a. Zìjié Tiàodòng), Beijing, China, or its subsidiaries, in which
any such company has any interest
So in order to pursue the same action against the NRA as Trump has against ByteDance, the President would also have to argue that any transaction with the NRA intrinsically involves an interest of a foreign company or a national thereof.
This argument could be made, and in fact, has been made by Democrats on the Senate Finance Committee, who released a report in September 2019 entitled The NRA and Russia which described the NRA as a "foreign asset". If a President were to attempt to argue this, it would likely be subject to some contention, as the Republican majority on that committee released a rebuttal report arguing that the original report "repeatedly attempts to paint a picture which does not exist".
