Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

On 26 December 2025 the President of Kazakhstan signed a law amending the Code "On Subsoil and Subsoil Use" with respect to the hydrocarbon and uranium sectors, followed on 30 December 2025 by a parallel set of amendments implementing presidential instructions on broader subsoil-use governance. Both packages take effect on 2 March 2026. The uranium amendments grant the National Atomic Company Kazatomprom (KAP) a statutory priority right to obtain exploration licences over prospective uranium areas listed in the State Subsoil Fund Management Programme, and to reserve blocks containing uranium mineralisation or deposits. Where uranium mineralisation is discovered on a solid-mineral block held by a third-party subsoil-user, an extension of that licence is conditional on the licensee surrendering the uranium-bearing block to the State; private subsoil-users no longer obtain priority production rights for uranium they discover. The amendments also raise the minimum direct or indirect Kazatomprom interest in any uranium mining project from 50% to 75%, and permit subsequent transfer to investors or joint-venture partners only subject to that 75% floor. The 30 December 2025 package establishes the National Geological Service as a non-privatisable national operator subordinate to the authorised subsoil-exploration agency and as the operator responsible for managing geological information; it also creates a Unified Subsoil Use Platform digital infrastructure (open geological-information database integrated with the Unified State System for Management of the Fuel and Energy Complex). The hydrocarbon track of the law shortens block-reservation periods and pushes unallocated plots into electronic-auction allocation to accelerate competitive exploration. The amendments accompany an announced USD 500m state geological-exploration programme.

On 6 November 2025 in Washington, DC, US Secretary of Commerce Howard Lutnick and Kazakhstan's Minister of Industry and Construction Yersayin Nagaspayev signed a bilateral Memorandum of Understanding on Critical Minerals Cooperation during President Kassym-Jomart Tokayev's state visit and the C5+1 Presidential Summit. The MoU establishes a framework for joint exploration, processing, and supply-chain transparency for tungsten, uranium, and rare-earth elements, with the explicit objective of building "resilient, non-Chinese supply-chains" for the global energy transition. The instrument is paired with up to USD 900 million in potential US financing to Cove Kaz Capital Group for tungsten development and sits inside a broader USD 17 billion package of Washington-signed agreements that lifts headline US-Kazakhstan economic engagement to a reported USD 117 billion.

On 23 October 2025, the Council of the European Union adopted the 19th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/2033 amending Regulation 833/2014 (sectoral sanctions), Council Implementing Regulation (EU) 2025/2035 amending Regulation 269/2014 (asset-freeze listings — 22 individuals + 42 entities, total 69 listings), and Council Regulation (EU) 2025/2041 (parallel Belarus measures). The package closes the Russian-LNG import loophole left open by the 18th package and establishes the architectural template for crypto-asset sanctions. Headline measures: (i) full prohibition on imports of Russian-origin LNG into the EU — short-term contracts banned six months from entry into force (effective 25 April 2026), long-term contracts (> 1 year, executed before 17 June 2025) phased out by 1 January 2027; (ii) full transaction ban on Rosneft and Gazprom Neft (tightening prior partial measures); (iii) five additional Russian banks added to Annex XIV transaction ban (Alfa-Bank, MTS Bank among them; effective 12 November 2025); (iv) full transaction bans on the Mir card payment system and the Faster Payments System (SBP), effective 25 January 2026; (v) first-ever EU sanctions on a stablecoin — the rouble-backed A7A5 (issuer + developer designated) — and a Paraguay-based cryptocurrency exchange used as a circumvention rail; (vi) prohibition on EU operators contracting with 11 listed Russian Special Economic Zones (Annex LII), with mandatory divestment from Alabuga (Tatarstan) and Technopolis Moscow effective 25 January 2026 — no five-year wind-down available; (vii) 45 entities added to Annex IV military end-user list (28 Russian + 17 third-country: 12 Chinese/Hong Kong, 3 Indian, 2 Thai); (viii) new export restrictions on electronic components, microelectronics, acyclic hydrocarbons, pneumatic rubber tires and propellant chemicals (~EUR 155 m of EU 2024 exports); (ix) prohibition on supply of AI, HPC, and quantum-computing services to Russian persons (effective 25 November 2025); (x) tourism-services ban (1 January 2026 wind-down); (xi) 117 additional shadow-fleet vessels listed (cumulative 557, exceeding the 18th package's 444); (xii) four Belarus + Kazakhstan banks listed for SPFS use (effective 2 December 2025); (xiii) binding ownership/control definitions added to Reg. 269/2014 (50 % proprietary-rights threshold + eight-criterion control test). Entry into force on 24 October 2025 (day following publication in OJ L_202502033), except for measures with explicit deferred application dates.

On 25 March 2025 the European Commission adopted the first list of 47 Strategic Projects inside the EU under Article 7 of the Critical Raw Materials Act (Regulation (EU) 2024/1252), followed on 4 June 2025 by 13 Strategic Projects located in third countries — 60 designations in total. The 47 EU projects span 13 Member States and 14 strategic raw materials, with an expected EUR 22.5bn capital-investment envelope; the 13 third-country projects require a further EUR 5.5bn. Designation triggers fast-track permitting (max 27 months for extraction, 15 months for processing/recycling), preferential access to EU/EIB/EBRD finance, and Member State priority status, operationalising the CRMA's 2030 benchmarks (≥10% extraction, ≥40% processing, ≥25% recycling, ≤65% single-country dependence).

On 18 October 2024 the Government of the Republic of Kazakhstan approved Government Resolution No. 868 adopting the Concept of Investment Policy of the Republic of Kazakhstan until 2029. The Concept sets a binding strategic-document target to attract at least US$150 billion in foreign direct investment over 2024-2029 and to raise fixed-capital investment from approximately 15.1% of GDP (2023) toward 23-25.1% of GDP by 2029. Its principal new instruments are (i) Development Bank of Kazakhstan (DBK / BDK) concessional lending at 6% interest for a 10-year tenor for the engineering infrastructure of new industrial projects, (ii) regional investment headquarters (one per oblast) modelled on the existing national Investment Headquarters under the Prime Minister, (iii) a national digital investment platform (invest.gov.kz) for streamlined permitting and investor aftercare, (iv) a unified register of investor issues and complaints administered by the Ministry of Foreign Affairs as the designated FDI-attraction owner, and (v) counter-obligations (localisation, employment, technology transfer) imposed on recipients of state preferences. The Concept is the principal implementing instrument under the 2021 Law on Industrial Policy (Law No. 86-VII ZRK) on the investment-attraction side and is designed to operate alongside the 2023 REE Comprehensive Plan and the 2025 Subsoil Code amendments on the minerals-extraction side.

The US Bureau of Industry and Security (BIS) final rule (89 FR 68544; FR Doc 2024-19130) added 123 entities under 131 entries to the Entity List with destinations Russia (63), China (42), Iran (11), Turkey (8), and one each in Canada, Cyprus, Kazakhstan, Kyrgyzstan, Crimea Region of Ukraine, Ukraine, and the United Arab Emirates. The dominant rationale is Russia-diversion enforcement: Chinese, Turkish and other third-country firms (e.g., MAK Logistics, Megatek Ltd., Wellgo International, AllChips Limited, Chipgoo Electronics) named for supplying U.S.-origin electronics and dual-use items to Russian industry and military, plus designation of large numbers of Russian military manufacturers (e.g., JSC 75 Arsenal, FSE Aleksinsky Chemical Plant) as military end users. License requirement is "all items subject to the EAR" with policy/presumption of denial; case-by-case for EAR99 food and medicine to certain Russian military end users. Effective on publication 2024-08-27.

The Department of Commerce Bureau of Industry and Security (BIS) added 91 entities (across 96 entries) to the Entity List under 15 CFR Part 744, in direct response to Russia's further invasion of Ukraine on 24 February 2022. The listed entities span ten destinations — Belize, Estonia, Kazakhstan, Latvia, Malta, Russia, Singapore, Slovakia, Spain, and the United Kingdom — and include Russian military research institutes, shipbuilding facilities, aerospace and electronics manufacturers, and suspected front companies in third countries used to circumvent EAR controls. A license is required for all items subject to the EAR; the review policy is denial for 86 entities and case-by-case (for US Government-supported space programs) for five.

On 27 December 2021 the Parliament of the Republic of Kazakhstan adopted Law No. 86-VII ZRK "On Industrial Policy" (Закон Республики Казахстан "О промышленной политике"), the horizontal framework statute that defines and governs the full toolkit of state-support instruments available to industrial entities — subsidies, in-kind grants, special economic zone (SEZ) regimes, industrial zone regimes, offtake guarantees, public-procurement preferences, long-term tariff agreements, and the "single card of industrialization" monitoring framework. The law replaced the earlier 2014 industrial-and-innovative-development statute and consolidated previously dispersed authority for the Ministry of Industry and Infrastructure Development (now Ministry of Industry and Construction) as the policy owner, with the Bank for Development of Kazakhstan (BDK / DBK) as the principal industrial- finance vehicle and Samruk-Kazyna and Tau-Ken Samruk as the state-equity vehicles. It is the enabling parent instrument under which all downstream Kazakh industrial-policy programmes (the 2023-12-28 REE Comprehensive Plan, the 2025-12-26 Subsoil Code amendments, the 18 October 2024 Investment Policy Concept until 2029, and the SEZ / industrial-zone regimes hosting Western FDI) operate. The statute has been amended eleven times between July 2022 and September 2025, including by Law 86-VIII ZRK of 21 May 2024 which revised Article 24 (state-support measures).

The US Department of Commerce preliminarily determined that producers and exporters of silicon metal from Kazakhstan received countervailable subsidies at a 120.00% economy-wide rate, and instructed US Customs and Border Protection to begin collecting cash deposits from importers at that rate. The countervailing-duty investigation was initiated 2020-07-27 following a June 2020 petition by Globe Specialty Metals, Inc. and Mississippi Silicon LLC, the same domestic petitioners behind the concurrent antidumping cases against Bosnia and Herzegovina, Iceland, and Malaysia. 2019 Kazakh silicon metal imports subject to the case were valued at approximately $14.9 million.

On 27 December 2017 President Nursultan Nazarbayev signed Code No. 125-VI ZRK "On Subsoil and Subsoil Use," a wholesale recodification replacing the 2010 Subsoil Use Law that entered into force on 29 June 2018 (with certain provisions deferred to 1 January 2019). The Code establishes the licensing architecture for all mineral extraction in Kazakhstan — the world's leading uranium producer (~40% of global U₃O₈ output, ~22,000 tU/yr) and a top-11 oil exporter (~1.8 mbpd) — covering solid minerals, hydrocarbons, and uranium under a single codified framework. For solid minerals the Code introduces a liberalised "first-come first-served" auction-free licence model for non-strategic deposits and a state-tender model for strategic deposits, alongside subsoil-use rights transfer and pledge provisions governing all M&A in the sector. For uranium the Code codifies the National Atomic Company Kazatomprom's statutory role as state operator over all uranium blocks, with government priority pre-emption rights and mandatory Kazatomprom participation in all production licences. For hydrocarbons the Code establishes the concession and production-sharing framework governing the pre-salt Caspian mega-projects (Tengiz, Karachaganak, Kashagan) and the model contract architecture for petroleum products. Horizontal obligations — local Kazakh-content procurement floors, social-package requirements, and environmental-restoration mine-closure security — apply across all subsoil-use categories. Structurally this Code is the parent statute for every subsequently filed KZ action: the 2023-12-28 REE Comprehensive Plan and the 2025-12-26 Kazatomprom uranium-priority amendments both operate under delegated authority created by this Code.