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Structured register of government actions in the geoeconomic space — export controls, tariffs, sanctions, FDI screening, subsidies, industrial-policy laws — cross-referenced into the country, minerals, and ETF surface. Charter: docs/IPTM_CHARTER.md.
Severity 1-5 is the qualitative impact rating (1=minor, 5=structural). The bilateral-trade-grounded quant scorer is the next IPTM milestone. RBI (Register Breadth Index) is a complementary structural-breadth indicator from scripts/py/iptm/breadth.py; divergence between RBI and severity is itself informative (high-sev / low-RBI = strategic chokepoint; low-sev / high-RBI = broad but shallow). Every action has at least one primary source URL. Verify-or-don't-file. See also themes, timeline, graph, sankey, map, country exposure, sector exposure, material exposure (+ graph), weekly briefs, portfolio scan, escalation monitor, trans-shipment hubs. Internal triage tools (RSS-poller candidate feed, source-feed health) live under /admin/candidates + /admin/sources. Subscribe via Atom feed (accepts ?country=CN, ?material=lithium, ?issuer=BIS, ?type=export_control, ?etf=SOXX, ?company=NVDA, ?minSeverity=4, ?year=2026, ?q=…) or pull /api/iptm/actions.
On 4 September 2026, OFAC issued Iran General License CC, authorizing wind-down of transactions involving Golden Global Yatırım Bankası, Golden Global Varlık Kiralama, and Golden Global Portföy Yönetimi (three linked Istanbul financial entities blocked the same day under E.O. 13902), through 12:01 a.m. EDT on 19 September 2026. On 8 September 2026, following SDN designation of 34 entities and one individual — chiefly Iranian passenger airlines (Air Shiraz, ATA Airlines, Iran Air Tour, Iran Aseman, Mahan-network carriers among others) and their UAE/UK/Malaysia/Kazakhstan support entities — and suspension of Iran General License J-1 (which had authorized reexport of civil aircraft to Iran), OFAC issued General License DD, authorizing wind-down of civil-aviation-related and other transactions previously authorized under the Iranian Transactions and Sanctions Regulations, through 12:01 a.m. ET on 23 September 2026. Both licenses were formally published in the Federal Register on 11 September 2026. Neither license relaxes the underlying restrictions; both are time-limited exit ramps administering an already-restrictive posture.
On 10 July 2026 OFAC issued Iran General License Y, authorizing the wind down of transactions involving Smart Global Limited (a Saint Kitts and Nevis holding company designated the same day alongside 5 other entities and 8 individuals), with payments to blocked parties to go into blocked accounts; it expired 9 August 2026. On 14 July 2026 OFAC issued General License Z under E.O. 13902, authorizing wind-down activity for blocked persons and vessels listed in an 11-entry annex (financial wind-down, safe port docking and departure, crew safety, emergency repairs, offloading of pre-14 July cargo); it expired 12 September 2026. Both licenses were formally published in the Federal Register on 23 September 2026 (91 FR 60304).
The U.S. Treasury's Office of Foreign Assets Control (OFAC) announced on 18 May 2026 that Adani Enterprises Limited (AEL), a flagship publicly traded entity of India's Adani Group (NSE: ADANIENT), agreed to pay $275,000,000 to settle apparent civil liability for violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 CFR Part 560) arising from AEL's purchases of liquefied petroleum gas (LPG) shipments through a Dubai-based commodity trader between November 2023 and June 2025, where red flags should have placed AEL on notice that the LPG originated from Iran. Approximately $192 million in payments for the Iranian-origin LPG shipments were processed through US financial institutions, providing the US nexus for OFAC jurisdiction. OFAC determined the apparent violations were EGREGIOUS and not voluntarily self-disclosed; AEL did not admit fault but committed to implementing enhanced compliance measures. The settlement is the largest OFAC enforcement action against an Indian corporate entity on record and was announced concurrently with parallel DOJ and SEC resolutions forming part of a broader US legal-relief package for the Adani Group.
On 23 April 2026, the Council of the European Union adopted the 20th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2026/506 amending Regulation 833/2014 (sectoral sanctions) and Council Regulation (EU) 2026/511 amending Regulation 269/2014 (asset-freeze listings — 120 additional individuals and entities, the largest single tranche in two years). The package operationalises and extends the crypto-sanctions architecture introduced in the 19th package and constructs the legal scaffolding for a future full prohibition on maritime services to vessels carrying Russian crude/petroleum products. Headline measures: (i) full sectoral prohibition on transactions with crypto-asset service providers and exchange platforms established in Russia or Belarus, plus designation of the rouble-backed stablecoin RUBx and the digital rouble (CBDC) on Annex LIII — effective 24 May 2026, with EU support for the digital rouble's development banned outright; (ii) 36 new energy-sector listings spanning upstream extraction, refining and transportation; (iii) prohibition on providing technical, financial, brokering and insurance services to Russia-flagged, Russian-certified or Russian-managed LNG tankers and icebreakers effective 25 April 2026, extending to foreign-flagged vessels operating in Russian interests by January 2027 and culminating in a categorical ban on LNG terminal services to Russian-controlled entities on 1 January 2027; (iv) full transaction ban on 20 Russian banks plus four third-country banks listed for SPFS connectivity / sanctions circumvention; (v) 46 newly listed shadow-fleet vessels and new tanker sale-due-diligence obligations on EU shipping operators; (vi) 58 designations of companies and associated individuals in the Russian military-industrial complex including drone developers/manufacturers; (vii) further Annex IV third-country circumvention enabler listings (China, Hong Kong, Turkey, UAE); (viii) parallel measures against Belarus. Entry into force on 24 April 2026 (day following publication in OJ L_202600506), except for measures with explicit deferred application dates.
On 7 February 2026 Ukrainian President Volodymyr Zelenskyy signed Presidential Decree No. 103/2026, enacting a National Security and Defence Council (NSDC) decision to apply personal special economic and other restrictive measures (sanctions) against 42 individuals and 35 legal entities based in Russia, Kyrgyzstan and the United Arab Emirates. The tranche specifically targets the "A7" cryptocurrency payment ecosystem, which Ukraine assesses is used to settle payments for components supplied for Russian missile production, alongside wider financial-sector sanctions-circumvention activity. Designation imposes asset freezes and a bar on commercial transactions and investment instruments involving the designees; the decree entered into force on 10 February 2026.
On January 23, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated eight vessel-owning/management firms — based in the UAE, India, Oman, the Seychelles, and the Marshall Islands — and identified nine of their tankers as blocked property, for transporting hundreds of millions of dollars' worth of Iranian crude oil, LPG, naphtha and high-sulfur fuel oil to buyers across East Asia, South Asia and East Africa. The action was taken under Executive Order 13902 (Iran petroleum/petrochemical sector) as part of the maximum-pressure campaign under National Security Presidential Memorandum 2, and OFAC concurrently issued General License T authorizing limited safety, environmental and cargo-offloading transactions involving the newly blocked vessels.
On 16 January 2026, the US Treasury's Office of Foreign Assets Control designated 21 individuals and entities and identified one vessel for transferring oil products, procuring weapons and dual-use equipment, and providing financial services to Iran-backed Ansarallah (the Houthis). Designated parties — oil-trading and exchange companies, a shipping/logistics facilitator, and front-company operatives — are based in Yemen, Oman, and the UAE, and are accused of running an oil-sales and financial- facilitation network that Treasury says generates the Houthis over $2 billion in annual illicit revenue. The action was taken pursuant to Executive Order 13224 (as amended) and builds on a multi-year cadence of prior OFAC designations against Houthi leaders, smugglers, financiers, and weapons-procurement suppliers.
The US Treasury's Office of Foreign Assets Control designated 18 individuals and entities that make up the "rahbar" shadow-banking networks of sanctioned Iranian banks Bank Melli and Shahr Bank, including Singapore-based Golden Mist PTE Ltd, UAE-based Empire International Trading FZE and HMS Trading FZE, Iran-based Nikan Pezhvak Aria Kish Company and Tejarat Hermes Energy Qeshm, and UK-based Nanshan Ltd. Separately, OFAC designated senior Iranian security officials, including SCNS Secretary Ali Larijani, for their role in the regime's violent crackdown on peaceful protesters that began in December 2025. The financial designations were made under E.O. 13902 (Iran's financial/petroleum/petrochemical sectors) and the human-rights designations under E.O. 13553 and E.O. 13876, in furtherance of NSPM-2; Treasury noted it sanctioned more than 875 persons, vessels, and aircraft under the same maximum-pressure campaign in 2025.
On 12 January 2026 Switzerland's Federal Department of Economic Affairs, Education and Research (WBF) amended Annexes 8, 14, 15b and 33 of the Ordinance on Measures in Connection with the Situation in Ukraine, with effect from 23:00 on 13 January 2026. The amendment adds 5 natural persons, 4 organisations (one Vietnam-based, three based in the UAE and Russia), and 41 vessels to the asset-freeze and port-access-prohibition annexes, and makes technical corrections to 7 existing entries. The measure is a routine incremental listing update continuing Switzerland's autonomous alignment with the EU's Russia sanctions regime, following the first EU 19th-package tranche adopted 12 December 2025 ([switzerland-19th-eu-sanctions-package-december-listings](2025-12-12-switzerland-19th-eu-sanctions-package-december-listings.md)) and preceding the substantive package completion of 25 February 2026 ([switzerland-19th-eu-sanctions-package-russia-belarus](2026-02-25-switzerland-19th-eu-sanctions-package-russia-belarus.md)).
HM Treasury's Office of Financial Sanctions Implementation (OFSI) published a Russia-regime notice on 18 December 2025 designating five individuals and 19 entities under the Russia (Sanctions) (EU Exit) Regulations 2019. Of the 19 entities, six are based in Russia, eight in the United Arab Emirates, four in Uzbekistan and one in Kyrgyzstan — reflecting OFSI's continued focus on third-country intermediaries used to route sanctioned Russian trade and finance. Designated persons are subject to a full asset freeze and are barred from commercial transactions and investment instruments with UK persons.
On December 18, 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated 29 shadow-fleet vessels and 17 vessel-management/shipping firms — plus Egyptian businessman Hatem Elsaid Farid Ibrahim Sakr and two of his UAE-registered companies (Red Sea Ship Management LLC and High Seas Petroleum LLC) — under Executive Order 13902 for operating in Iran's petroleum sector. The vessels, flagged across Palau, Panama, Cook Islands, Barbados, Jamaica and unknown registries, are said to have transported "hundreds of millions of dollars'" worth of Iranian crude oil, fuel oil, bitumen, naphtha and condensate to buyers in Asia. Treasury frames the action as part of a campaign that has sanctioned more than 180 vessels since President Trump resumed office in January 2025, implementing NSPM-2 maximum-pressure policy.
On 15 December 2025 the Council of the European Union adopted Council Implementing Regulation (EU) 2025/2588 and Council Decision (CFSP) 2025/2594, giving effect to Regulation (EU) No 269/2014 (Ukraine territorial-integrity asset-freeze regime) by adding 9 new designations: 5 individuals who own or control companies enabling Russian oil shipments and controlling a significant share of Russia's "shadow fleet," and 4 shipping companies headquartered in Russia, the United Arab Emirates and Vietnam that manage shadow-fleet tankers and engage in irregular, high-risk shipping practices. Listed persons and entities are subject to an EU asset freeze (and, for the individuals, a travel ban); EU persons and companies are prohibited from making funds or economic resources available to them.
On 12 December 2025 the Swiss Federal Council adopted the first tranche of listings aligning with the EU's 19th Russia sanctions package (Council Regulation (EU) 2025/2033, 23 October 2025), amending the Ordinance on Measures in Connection with the Situation in Ukraine and the Belarus Ordinance with effect from 13 December 2025. The decision adds asset freezes and entry/transit bans for 22 natural persons and 42 entities tied to Russia's military-industrial complex, energy sector and shadow-fleet vessel management; extends purchase/sale/insurance bans to over 100 additional tankers; imposes transaction restrictions on 5 Russian banks and 4 Russian-bank branches in Belarus and Kazakhstan for use of specialised financial-messaging services; sanctions Chinese and Hong Kong trading companies and refineries implicated in circumventing the G7 oil price cap; and designates 5 Belarusian persons linked to military-industrial activities. Divestment-exemption deadlines for Swiss persons winding down Russian holdings are extended to end-2026. This is a partial, listings-only tranche — the more substantive measures of the EU's 19th package (Russian LNG import ban, crypto-services prohibition, AI/HPC service bans) were not adopted until the Federal Council's follow-on decision of 25 February 2026.
The US Treasury's Office of Foreign Assets Control designated 32 individuals and entities based in Iran, the UAE, Turkiye, China, Hong Kong, India, Germany and Ukraine for operating procurement networks that supply Iran's ballistic missile and UAV programmes, including missile propellant precursors and UAV components. The action is Treasury's second round of nonproliferation sanctions since the 27 September 2025 reimposition of UN sanctions on Iran ("snapback") over its non-compliance with international nuclear and missile commitments. Designated entities include Iran-based Kimia Part Sivan Company (KIPAS), which Treasury says has worked with the IRGC-Qods Force to advance Iran's UAV programme. All property and interests of the designated parties subject to US jurisdiction are blocked, and US persons are generally prohibited from transacting with them.
On 9 October 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated more than 50 individuals, entities and vessels for facilitating Iranian crude oil, petroleum-product and liquefied petroleum gas (LPG) exports, in a coordinated action with the State Department. The network included 33 vessels transporting Iranian crude and LPG, shipping entities registered in Panama, the Marshall Islands, Ukraine and Liberia, an Iranian petrochemical producer, four Turkish petrochemical trading entities, five Chinese entities importing/refining/storing Iranian petroleum (including a China-based petrochemical-terminal operator, Jiangyin Foreversun Chemical Logistics Co., Ltd.), three Singapore-based logistics entities, and 27 entities based in Hong Kong, the UAE and India engaged in trading and shipping. The action was taken pursuant to the National Security Presidential Memorandum 2 (NSPM-2) maximum-pressure campaign against Iran and blocks all US property/interests of the designated parties, exposing non-US counterparties to secondary-sanctions risk.
The US Treasury's Office of Foreign Assets Control designated two Iranian financial facilitators — Alireza Derakhshan and Arash Estaki Alivand — along with more than a dozen Hong Kong- and UAE-based individuals and entities for operating a shadow-banking network that laundered proceeds from Iranian oil sales through front companies and cryptocurrency. The designated addresses account for over $600 million in total inflows, including more than $100 million in cryptocurrency purchases tied to oil sales between 2023 and 2025. Proceeds are alleged to benefit the IRGC-Qods Force and Iran's Ministry of Defense and Armed Forces Logistics (MODAFL). This is the second round of OFAC sanctions targeting Iran's shadow-banking infrastructure since National Security Presidential Memorandum 2 (NSPM-2) directed a maximum-pressure campaign on Iran in February 2025.
On 11 September 2025, the US Treasury's Office of Foreign Assets Control designated 32 individuals and entities and identified four vessels in what Treasury described as its broadest sanctions action to date against Iran-aligned Ansarallah (Houthi) support networks. The designated network — companies, owners, and operatives located in Yemen, China, the UAE, and the Marshall Islands — is accused of running oil and commodity smuggling through Houthi-controlled Yemeni ports, laundering the proceeds, and using them to finance a global weapons procurement supply chain of front companies and shipping facilitators. The action was taken pursuant to Executive Order 13224 (as amended) and builds on nine prior 2024-2025 OFAC actions against Houthi leaders, smugglers, financiers, and suppliers.
On 2 September 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated Waleed Khaled Hameed al-Samarra'i, a dual Iraqi/St Kitts-and-Nevis citizen, along with his UAE-based shipping manager Babylon and five Marshall Islands-registered shell companies (Tryfo Navigation, Keely Shiptrade, Odiar Management, Panarea Marine, Topsail Shipholding) that hold registered ownership of nine Liberia-flagged tankers (ADENA, LILIANA, CAMILLA, DELFINA, BIANCA, ROBERTA, ALEXANDRA, BELLAGIO, PAOLA). The network blends Iranian crude with Iraqi oil via ship-to-ship transfers in the Arabian Gulf and at Iraqi ports, then markets the blend as solely Iraqi-origin to evade US sanctions, generating hundreds of millions of dollars for the Iranian regime and al-Samarra'i. The action was taken pursuant to Executive Order 13902 and blocks all US property and interests of the designated individual, entities and vessels.
On 30 July 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated more than 50 individuals and entities and identified more than 50 vessels belonging to the shipping empire of Mohammad Hossein Shamkhani, son of Ali Shamkhani, a top political adviser to Iran's Supreme Leader. Treasury described the action — over 115 sanctions in total — as its largest Iran-related action since 2018. The network launders billions of dollars from sales of Iranian and Russian crude oil and petroleum products (mostly to buyers in China) through vessels and front companies registered across the UAE, Hong Kong, India, Cyprus, Panama, Romania, China, Liberia, the Marshall Islands and Seychelles. Concurrently, the State Department designated 20 entities and identified 10 vessels under E.O. 13846 and E.O. 13902 for trading and transporting Iranian petroleum and petrochemical products.
On 22 July 2025, the US Treasury's Office of Foreign Assets Control designated two individuals and five entities under Executive Order 13224 for facilitating revenue generation and material support to the Houthis (Ansarallah) through petroleum importation and money laundering. The network — Muhammad Al-Sunaydar's Arkan Mars petroleum companies (Yemen/UAE) and Yahya Mohammed Al Wazir's Al-Saida Stone for Trading and Agencies and Amran Cement Factory — coordinated roughly $12 million of Iranian petroleum imports through the Houthi-controlled Ras Isa port with an Iranian IRGC-linked petrochemical trading entity, and laundered approximately €6 million through bulk-coal front-company transactions. The action builds on a cadence of OFAC designations against Houthi revenue and weapons-procurement networks running since mid-2024.
On 18 July 2025, the Council of the European Union adopted the 18th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/1494 amending Regulation 833/2014 (sectoral measures), Council Implementing Regulation (EU) 2025/1476 implementing Regulation 269/2014 (asset-freeze listings), Council Decision (CFSP) 2025/1495 (vessel listings), and Council Regulation (EU) 2025/1472 (parallel Belarus measures). The package is the largest energy-sector escalation since 2022 and pivots from new-perimeter creation toward enforcement and circumvention closure. Headline measures: (i) the Russian-crude price cap is lowered from USD 60 to USD 47.6 per barrel with a new automatic dynamic mechanism re-indexing the cap to global oil prices every six months at a 15 % discount to the 22-week trailing average (effective 3 Sep 2025, with a transitional exemption to 18 Oct 2025 for pre-20 Jul 2025 contracts compliant with the prior cap); (ii) full transaction ban extended to 22 additional Russian banks, bringing the total cut off from the EU financial system to 45; transaction ban extended to third-country financial institutions and crypto-asset service providers facilitating circumvention; (iii) full transaction ban on Nord Stream 1 and Nord Stream 2 pipelines; (iv) import ban on refined oil products derived from Russian crude processed in third countries; (v) 105 additional vessels added to the shadow-fleet port-access ban (cumulative total 444); (vi) 26 new entities added to Annex IV military end-user list (15 Russian + 11 from China/Hong Kong/Turkey); (vii) Council Implementing Regulation 2025/1476 lists 14 individuals + 41 entities under asset-freeze, including a major Indian refinery (Nayara Energy, part-owned by Rosneft), three Chinese suppliers of battlefield goods, shadow-fleet operators, and entities involved in the deportation of Ukrainian children; (viii) parallel Belarus complementary measures via Regulation 2025/1472. Wind-down periods vary: 90 days for oil-price-cap contracts; banking-software wind-down to 30 Sep 2025; trade-goods wind-downs Oct 2025–Jan 2026 by category. Entry into force on 19 July 2025 (day following publication in the Official Journal), except for measures with explicit deferred application dates.
The US Treasury's Office of Foreign Assets Control designated 22 entities based in Hong Kong (18), the UAE, and Türkiye under Executive Order 13224 for facilitating sales of Iranian oil that benefit the IRGC-Qods Force (IRGC-QF), a designated Foreign Terrorist Organization. The front-company network moves refinery payments for Iranian oil through offshore accounts to fund IRGC-QF activity; the action is the second round of sanctions under National Security Presidential Memorandum 2's "maximum pressure" campaign, following a June 6, 2025 action against Iranian exchange-house money-laundering networks. All property and interests of the designated entities within US jurisdiction are blocked, and US persons are generally prohibited from dealing with them.
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced on 8 July 2025 that Harman International Industries, Inc. agreed to pay $1,454,145 to settle potential civil liability for 11 apparent egregious violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 CFR Part 560) that occurred between 22 May 2018 and 27 October 2020. Overseas employees of a U.S. subsidiary of Harman — a Samsung-owned consumer-electronics and automotive-electronics company headquartered in Stamford, CT — enabled the diversion of consumer-audio products through Harman's UAE distributor to end-users in Iran with knowledge that the distributor was reselling into Iran in violation of the ITSR. OFAC determined the apparent violations were egregious but voluntarily self-disclosed, and Harman agreed to invest $400,000 in additional compliance measures as partial satisfaction of the settlement amount.
On 3 July 2025, the US Treasury's Office of Foreign Assets Control designated a network of UAE- and UK-based companies controlled by Iraqi-British businessman Salim Ahmed Said that has smuggled Iranian oil disguised as Iraqi crude since at least 2020, plus five additional shadow-fleet vessel owners based in Seychelles, the Marshall Islands, and the British Virgin Islands. The action, taken pursuant to E.O. 13902 (Iran petroleum sector) and E.O. 13224 (counterterrorism), also identifies several tankers as blocked property and marks the eighth round of sanctions under National Security Presidential Memorandum 2's Iran maximum-pressure campaign. Concurrently, the State Department designated six additional entities and four vessels under E.O. 13846.
Canada made SOR/2025-142, Regulations Amending the Special Economic Measures (Russia) Regulations, registered 2025-06-13. The regulations add 34 Russian entities to Part 2 of Schedule 1 alongside Keremet Bank Open Joint-Stock Company (Kyrgyzstan), three UAE-based entities, one Singapore-based entity, and two energy-commodity trading companies (Switzerland, Azerbaijan) — all designated as sanctions-evasion intermediaries for Russian trade. The amendments also add 201 vessels (by IMO number) to Schedule 1.1 as part of Russia's "shadow fleet," triggering a dealings ban, asset freeze, and a new prohibition on providing financial or other services to non-Canadians in relation to a listed vessel.
The US Treasury's Office of Foreign Assets Control designated more than 35 individuals and entities tied to Iranian brothers Mansour, Nasser, and Fazlolah Zarringhalam, whom OFAC says have collectively laundered billions of dollars through the international financial system using Iranian exchange houses (including Zarrin Ghalam, GCM Exchange, and Berelian Exchange) and foreign front companies based in the UAE and Hong Kong. The network is used to move revenue from Iranian oil and petrochemical sales that fund the regime's nuclear and missile programs and terrorist proxies. The action, taken pursuant to Executive Order 13902, is the first designation round under National Security Presidential Memorandum 2's "maximum pressure" campaign since its February 4, 2025 issuance; Treasury's FinCEN concurrently issued an updated advisory on Iranian shadow-banking and oil-smuggling red flags for financial institutions.
On 30 April 2025 the US Department of State designated seven entities and identified two vessels as blocked property for facilitating trade in Iranian petroleum and petrochemical products, under Executive Order 13846 and in furtherance of National Security Presidential Memorandum 2 (NSPM-2, "Restoring Maximum Pressure on the Government of Iran"). The action named four UAE-based sellers and one purchaser of Iranian petrochemicals — including Solvent Organics (over $300 million in exports of Iranian-origin petrochemicals to third countries) and Alseerah Trading (over $150 million) — plus a Turkiye-based petrochemical trader, an Iran-based cargo inspection company, and a marine management company involved in transporting millions of barrels of Iranian crude. Secretary of State Marco Rubio stated the goal was to drive Iran's illicit oil and petrochemical exports, including to China, to zero.
On 19 October 2022, the US Treasury's Office of Foreign Assets Control (OFAC) designated Russian national Yury Yuryevich Orekhov, resident in Dubai, UAE, under Executive Order 14024 for operating a network that procured military and sensitive dual-use technology from Western suppliers for Russian end-users. Two entities tied to Orekhov were designated alongside him: NDA Nord-Deutsche Industrieanlagenbau GmbH, based in Hamburg, Germany, and Opus Energy Trading LLC, based in Dubai, UAE. The designation blocks all US property and interests of the designated persons and generally prohibits US persons from transacting with them.