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The announced sanctions actions are being carried out in a manner that implements NSPM-2 of 2025.
The U.S. State Department press statement (Jan 15, 2026) explicitly states the sanctions action "further implements National Security Presidential Memorandum-2 of 2025." The Department of the Treasury/OFAC press release for the same measures also says the designations are taken "in furtherance of the President's National Security Presidential Memorandum 2 (NSPM-2)" and describes sanctions targeting Iran’s petroleum/financial sectors and shadow-banking networks. Verdict: True — official U.S. government documents explicitly link the Jan 15, 2026 sanctions to NSPM-2, and the actions announced align with NSPM-2’s directives to impose maximum pressure on Iran’s financial, petroleum, and sanctions-evasion networks.