Congress prematurely authorized the entry into negotiations and agreement of executive officers with foreign governments, approved the borrowing of 392 abroad and the money acquired to pay the government of Al giers to prevent pirate attacks against American shipping. 393 Perhaps the first formal authorization, ahead of an executive agreement, was the adoption of a statute allowing the postmaster to “make arrangements with the postmasters in any foreign country for the mutual receipt and distribution of letters and parcels through post offices.” 394 Congress also approved, usually by resolution, other executive agreements, such as the annexation of Texas and Hawaii and the acquisition of Samoa. 395 A successful source of executive agreements has been the approval of reciprocal agreements between the United States and other countries to ensure the protection of patents, copyrights and trademarks. 396 In the United States, executive agreements are binding at the international level if they are negotiated and concluded under the authority of the President on foreign policy, as commander-in-chief of the armed forces or from a previous congressional record. For example, the President, as Commander-in-Chief, negotiates and concludes Armed Forces Agreements (SOFAs) that govern the treatment and disposition of U.S. forces deployed in other nations. However, the President cannot unilaterally enter into executive agreements on matters that are not in his constitutional jurisdiction. In such cases, an agreement should take the form of an agreement between Congress and the executive branch or a contract with the Council and the approval of the Senate.  International organizations .–The overlap of contractual power through cooperation between Congress and the executive branch in international agreements is also demonstrated by the use of resolutions that approve U.S. membership in international organizations 408 and participation in international conventions. 409 The Case-Zablocki Act of 1972 requires the President to notify the Senate within 60 days of an executive agreement. The president`s powers to conclude such agreements have not been restricted. The reporting requirement allowed Congress to vote in favor of repealing an executive agreement or to refuse funding for its implementation.
  Executive agreements are often used to circumvent the requirements of national constitutions for treaty ratification. Many nations that are republics with written constitutions have constitutional rules on treaty ratification.