ExecutiveOrdersEO
Det 2026-01DeterminationTrump 47 · R Quiet signal

Presidential Determination 2026-01

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

This presidential determination finds that global petroleum markets have sufficient non-Iranian supply to allow significant reductions in Iranian oil purchases through foreign financial institutions. It continues the sanctions framework under NDAA FY2012 that restricts foreign financial institutions from processing Iranian oil transactions. The determination maintains existing policy without imposing new restrictions or lifting current ones.

Federal Register Open PDF 90 FR 59709

Impact dates

  1. Continued presidential monitoring of petroleum market conditions

  2. Federal Register publication by Secretary of State

Market exposure

Policy exposure mapping — not investment advice. Illustrative public companies are incomplete and not recommendations.

Sectors

Oil & gasShipping & logisticsBanking & finance

Mechanisms

Ban / prohibitionLicensing

Role pressure

  • AdverseImporter — Foreign financial institutions facilitating Iranian oil purchases remain exposed to US sanctions; significant reduction required
  • ProtectiveTrading-partner exporter — Non-Iranian petroleum producers benefit from maintained market access and continued displacement of Iranian supply
  • MixedDownstream manufacturer — Stable global supply assessment reduces price spike risk, but sanctions compliance costs persist

Geographies

USCNINKRJPEUOTHER

Illustrative public companies

Curated watchlist matches by sector/role — incomplete; not a recommendation.

DACDanaosFDXFedExHSBCHSBCSHELShellTSLATeslaUPSUPSZTOZTO Express

Confidence: medium · Policy alerts

Key directives

  • Determine sufficient non-Iranian petroleum supply exists to permit significant reduction in Iranian oil purchases
  • Continue monitoring global petroleum market conditions
  • State Department to publish determination in Federal Register

Who is ordered

Timeline

Immediate

  • Determination takes effect upon signing; foreign financial institutions remain exposed to sanctions for significant Iranian oil transactions

Near term (90d)

  • Continued monitoring by President; State Department publication in Federal Register

Long term

  • Ongoing sanctions architecture against Iranian petroleum sector maintained; periodic determinations required to sustain exemption framework

Risks & tensions

  • Determination is 'consistent with prior determinations' suggesting continuity, not escalation or relaxation
  • Vague 'continue to monitor' language provides flexibility but no concrete trigger for policy change
  • Global spare capacity and strategic reserves mentioned as factors; actual market tightness uncertain
  • Timing (November 2025, post-October 2025 EIA report) suggests routine administrative renewal
Presidential Determination 2026-01: Presidential Determination Pursuant to Section 1245(d)(4)(B) and (C) of the National Defense Authorization Act for Fiscal Year 2012 · Executive Orders