Industrial Policy & Trade Monitor· 2666 actions· ✨ 90 recent

On May 1, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated China-based independent ("teapot") refinery Hengli Petrochemical (Dalian) Refinery Co., Ltd. — described as China's second-largest teapot — together with approximately 40 shipping firms and vessels operating as part of Iran's shadow fleet. OFAC sanctioned 19 shadow-fleet vessels (crude, LPG, and petrochemical tankers) as blocked property of designated owners or managers. The action was taken under Executive Order 13902 (Iran petroleum and petrochemical sectors) in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. Treasury press release SB0472. Concurrent with the designations, OFAC issued Iran-related General License W authorising the wind-down of transactions involving the persons newly blocked on May 1, 2026, and published a structurally novel Iran-related Alert, "Sanctions Risks of Iranian Demands for Strait of Hormuz Passage." The Alert states that payments to the Government of Iran or the IRGC — directly or indirectly — for safe passage through the Strait of Hormuz are not authorised for US persons (including US financial institutions) or US-owned/-controlled foreign entities. OFAC also issued new FAQ 1250 to accompany the Alert and GL W. The wave is one of the largest single-day Iran enforcement actions of the Trump 2.0 administration. Treasury characterises it as part of a campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The Strait of Hormuz Alert is the operational US response to Iranian regulatory threats against the ~20% of global oil and ~25% of global LNG transiting Hormuz, putting tanker owners, P&I clubs, flag states, and oil-buyer compliance teams on direct notice.

On April 24, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) added 19 entities and 19 vessels to the Specially Designated Nationals (SDN) List under Executive Order 13902 (Iran petroleum and petrochemical sectors), in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. The action is the first OFAC designation of a Chinese independent ("teapot") refinery — Hengli Petrochemical (Dalian) Refinery Co., Ltd., described as one of Iran's largest single customers for crude oil and petroleum products, having purchased billions of US dollars' worth since at least 2023 from cargoes brokered by Sepehr Energy Jahan Nama Pars Company (the oil sales arm of Iran's Armed Forces General Staff, controlled by the Ministry of Defense / MODAFL). Co-designations span shipping firms and vessels registered in China, Hong Kong, Panama, Marshall Islands, Liberia, and Vietnam. Concurrent with the designations, OFAC issued Iran-related General License V authorising a 30-day wind-down (through May 24, 2026) of transactions involving Hengli Petrochemical (Dalian) Refinery Co., Ltd. and certain majority-owned entities. Treasury press release SB0472 ("Economic Fury Targets Global Network Fueling Iran's Oil Trade and Shadow Fleet") frames the action as part of the maximum-pressure campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The April 24 designations directly triggered the first-ever operational use of China's Blocking Rules (MOFCOM Announcement No. 21 of May 2, 2026) and preceded a second OFAC Iran wave on May 1, 2026 (General License W + Strait of Hormuz Sanctions Risk Alert).

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 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.

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.

The Pleno of Panama's Supreme Court of Justice unanimously declared Law 406 of 20 October 2023 — which ratified the renewed mining-concession contract between the Panamanian State and Minera Panamá S.A. (a subsidiary of Canada's First Quantum Minerals) — unconstitutional in its entirety. The ruling, delivered 27 November 2023 and published in Gaceta Oficial No. 29922 on 2 December 2023, found violations of 25 constitutional articles and ordered the orderly closure of the Cobre Panamá open-pit copper mine, which had produced ~350,000 t/yr of copper (~1% of global mined supply) and accounted for ~5% of Panama's GDP. The decision triggered a de-facto Panama-wide moratorium on new large-scale metals concessions and pending ICSID arbitration claims by First Quantum and Korea Resources / KORES (COFINPRO).

Panama's Asamblea Nacional enacted Ley 407 on 3 November 2023, sanctioned by President Laurentino Cortizo Cohen and published in Gaceta Oficial Digital N° 29904 of the same date. The law declares an indefinite moratorium on the granting of concessions for exploration, extraction, transportation, and benefit of metallic mining throughout national territory under the precautionary principle, bars the Ministerio de Comercio e Industrias (MICI) from issuing any new concessions and requires flat rejection of all pending applications from the date of enactment. Ley 407 constitutes the legislative instrument in the paired judicial-legislative architecture under which Panama effectively exits large-scale metals mining: it operates as the prospective, horizontal concession ban, while the Corte Suprema's November 2023 Sentencia (filed separately) is the retrospective judicial nullification of the Cobre Panamá contract. Together they structurally withdraw ~1% of global mined copper supply and affect ~5% of Panama's GDP.