Presidential Determination on the Pursuant to Section 1245(d)(4)(B) and (C) of the National Defense Authorization Act for FY 2012

Energy & Environment Defense & Security Trade

In simple terms

President Trump determined that global petroleum supplies from non-Iranian sources remain sufficient to allow significant reductions in Iranian oil purchases, continuing a sanctions mechanism under the 2012 NDAA. The finding maintains the legal foundation for pressuring foreign buyers to cut Iranian oil imports.

Federal Register Open PDF 86 FR 7789

Record & deadlines

Jan 14, 2021Signed
Signed by the President
Feb 2, 2021FR published
Published in the Federal Register · 86 FR 7789
Federal Register PDF
Date TBD
Secretary of State to publish determination in Federal Register

Key directives

Determine sufficient non-Iranian petroleum supply exists per 2012 NDAA Section 1245(d)(4)(B) and (C)
Continue monitoring global oil supply situation
Secretary of State to publish determination in Federal Register

Who is ordered

What to expect

Immediate

Determination takes effect upon signing; maintains existing sanctions framework

Near term (90d)

Secretary of State to publish in Federal Register

Long term

Continued monitoring of global oil supply conditions; potential future determinations required periodically

Risks & tensions

Document text is vague on publication timing—'authorized and directed' without specific deadline
Maintains pressure on Iran but avoids escalation; consistent with prior determinations suggesting policy continuity
Reliance on EIA data from October 2020 may not reflect rapidly changing market conditions
Biden administration taking office January 20, 2021 creates uncertainty about enforcement approach