Trump issues presidential determination on Iran sanctions under 2012 defense law

President Donald Trump signed a Presidential Determination Pursuant to Section 1245(d)(4)(B) and (C) of the National Defense Authorization Act for Fiscal Year 2012 on May 7, 2026, the Executive Office of the President announced in a notice published in the Federal Register on May 13.

The determination applies to foreign financial institutions, energy firms, and governments engaged in petroleum transactions with Iran. Section 1245 of the 2012 law requires sanctions on entities that purchase Iranian oil or conduct significant financial transactions with Iran's Central Bank, with the presidential authority to issue findings that either trigger or adjust those measures.

The Federal Register notice contains no new dollar thresholds, percentage reductions in purchases, or named countries subject to fresh penalties.

The action leaves the prior sanctions enforcement baseline unchanged. No new effective date is specified in the notice; the determination maintains the operational status that existed before May 7. Foreign entities already compliant with existing U.S. restrictions on Iranian crude oil continue under the same rules, while those previously identified for sanctions remain so.

Downstream, the Treasury Department must continue to implement and enforce the sanctions list as written, including any required notifications to Congress under the underlying statute. Banks and energy traders operating in jurisdictions that import Iranian oil must monitor the unchanged compliance thresholds for the next reporting cycle.

The State Department retains responsibility for any subsequent diplomatic notifications to partner governments. No immediate regulatory deadlines shift as a result of this specific determination.

This is the latest presidential action taken under the 2012 National Defense Authorization Act's Iran sanctions title. The statute has served as the legal basis for successive administrations to calibrate secondary sanctions on Iran's energy exports since its enactment in December 2011.

Congress has revisited Iran sanctions provisions in subsequent defense authorization bills without repealing the core Section 1245 authorities cited in the May 7 determination.