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

This determination continues a long-standing policy by finding that global petroleum supplies from non-Iranian sources are sufficient to allow foreign financial institutions to significantly reduce purchases of Iranian oil without harming oil markets. This sustains the sanctions framework under Section 1245 of the FY2012 NDAA, which conditions access to the U.S. financial system on countries significantly reducing Iranian oil imports.

Federal Register Open PDF 89 FR 46015

Impact dates

Date TBD
Federal Register publication by Secretary of State

Key directives

Determine that non-Iranian petroleum supply is sufficient to permit significant reduction in Iranian oil purchases
Direct Secretary of State to publish determination in Federal Register
Continue monitoring global oil supply situation

Who is ordered

Timeline

Immediate

Determination takes effect upon signing, maintaining existing sanctions framework
Secretary of State directed to publish in Federal Register

Near term (90d)

Continued monitoring of global oil supply conditions by the President

Long term

Ongoing enforcement of Iran oil sanctions through U.S. financial system access restrictions
Potential for future determinations based on changed market conditions

Risks & tensions

Determination is 'consistent with prior determinations' suggesting continuity rather than policy shift; no explicit revocation or change from previous administration's stance
Vague on whether this maintains or tightens enforcement posture—'consistent with prior determinations' could span multiple administrations
Global oil market conditions (spare capacity, strategic reserves) are dynamic; determination may become outdated if supply disruptions occur