The Oct. 28 decision concludes that petroleum available outside Iran could support a substantial reduction in purchases routed through foreign financial institutions.
The Federal Register published the determination, No. 2027-02, on Nov. 13.
Section 1245(d)(4)(B) and (C) of the National Defense Authorization Act for Fiscal Year 2012 sets the standard. At least every 180 days, the president must assess whether the price and supply of petroleum from countries other than Iran can support significant reductions in Iranian purchases made by or through foreign financial institutions. An affirmative finding is one condition for sanctions to apply to transactions conducted or facilitated by a foreign financial institution involving purchases of Iranian petroleum, subject to statutory exceptions.
The memorandum cites Energy Information Administration reporting, including an October 2026 report, alongside economic conditions and strategic-reserve availability. Addressed to the secretaries of State, Treasury and Energy, it says the president will continue monitoring the situation and describes the determination as consistent with earlier ones.
