National Security Presidential Memorandum 2 (NSPM-2)

National Security Presidential Memorandum 2 (NSPM-2) is a US presidential directive addressing the proliferation of Weapons of Mass Destruction. Originally issued as a Cold War-era authority, the framework authorises the Treasury Department's Office of Foreign Assets Control (OFAC) to designate entities involved in Ballistic missile, nuclear, and drone procurement chains without requiring a new executive order for each round of sanctions.

During the 2026 Iran war, NSPM-2 has become one of the primary legal instruments enabling OFAC to run five nonproliferation sanctions rounds without a signed Trump executive order. OFAC's bulletin sb0465 on 24 April 2026, which designated 14 individuals, entities, and aircraft across Iran-Turkey-UAE procurement chains including Mahan Air's EP-MTB, cited NSPM-2 alongside the September 2025 UN Security Council snapback as its legal authority.

NSPM-2's role in the Iran war illustrates the instrument gap: the White House has signed zero Iran-specific executive instruments in 55 days of conflict, yet OFAC, the Pentagon, and CENTCOM have each reached for standing authorities that bypass signed presidential paper. NSPM-2 is the Treasury variant of this pattern, enabling proliferation designations to continue as administrative acts under pre-existing presidential authority rather than new executive action.