Industrial Policy & Trade Monitor· 2662 actions· ✨ 89 recent

On June 2, 2026, USTR published final actionability findings in 60 parallel Section 301(b) investigations — the largest simultaneous Section 301 action in US history — determining that all 60 economies maintain unreasonable acts, policies, or practices by failing to impose or effectively enforce a prohibition on imports produced with forced labor. USTR proposed two additional duty rates: 10% on the 14 economies with partial forced-labor regimes (Canada, Ecuador, EU, Indonesia, Mexico, Pakistan, Argentina, Bangladesh, Cambodia, El Salvador, Guatemala, Malaysia, Taiwan, UK) and 12.5% on the remaining 46 economies. Tariff rates remain proposed pending a July 7, 2026 public hearing and subsequent finalization; the actionability determination is final.

On 26 May 2026 the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, imposed a £1,000,920.59 monetary penalty on Sabre Global Technologies Limited (SGTL), a UK-registered travel-technology firm, for repeated breaches of UK financial sanctions. SGTL continued to provide Russian carrier Ural Airlines access to its Global Distribution System (GDS) service for seven months after Ural Airlines was designated by the UK in May 2022, and during July–August 2022 actively explored routing payments through a US bank account to avoid detection by its UK bank — the conduct that makes this the **first OFSI penalty issued for a circumvention offence**. At £1,000,921 this is also OFSI's **largest financial-sanctions penalty since Russia's 2022 invasion of Ukraine**, surpassing the prior record (HSF £465k).

The UK laid the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (SI 2026/543) before Parliament on 19 May 2026; it came into force on 20 May 2026. The instrument inserts a new Chapter 4KA (regulations 46Z23A-46Z23G) into the Russia (Sanctions) (EU Exit) Regulations 2019, prohibiting the import into the UK of uranium (HS 2844.10/2844.20/2844.30) that originates in or is consigned from Russia, the direct or indirect acquisition of Russian-origin or Russia-located uranium, and the supply or delivery of uranium from Russia to a third country — plus associated technical assistance, financial services/funds, and brokering services. Each prohibition carries a criminal offence with a reasonable-cause-to- suspect defence, subject to narrow exceptions and licensing grounds at regulations 16-19 of the amending instrument. The same instrument separately extends the existing ban on imports of relevant (2709-origin) Russian crude to cover oil products refined from that crude in a third country (new regulations 46Z9F-46Z9I).

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.

Resolution of the Government of the Russian Federation No. 431 of 17 April 2026, signed by Prime Minister Mikhail Mishustin, sets temporary export quotas on mineral fertilisers from Russia for the six-month period 1 June – 30 November 2026. The aggregate quota is approximately 20 million tonnes, comprising over 8.7 Mt for nitrogen fertilisers (urea, ammonium sulphate, UAN), over 4.2 Mt for ammonium nitrate (a separate sub-quota, suspended from 21 March – 21 April 2026 before this cycle opened), and over 7 Mt for complex fertilisers (NPK, NP, NPS, DAP, MAP). The measure continues the recurring six-month quota architecture in place since late 2021 and is the direct successor to the Dec 2024 – May 2025 cycle fixed under Resolution 1400 of October 2024 (and its subsequent extensions). Exemptions apply to EEU members, Abkhazia, South Ossetia, humanitarian-aid lots, and transit flows.

On 13 April 2026 the Council of the EU and the European Parliament reached a provisional political agreement, in trilogue with the Commission, on the new EU steel safeguard regulation that will replace the existing WTO-safeguard-based measure (Regulation (EU) 2019/159, last tightened by Implementing Regulation 2025/612) expiring on 30 June 2026. The agreement adopts the core architecture of the Commission's October 2025 proposal (procedure 2025/0726(COD)): an overall duty-free tariff-rate quota of approximately 18.3 million tonnes per year — a roughly 47% reduction versus the 2024 safeguard quotas — covering 30 product categories, with the out-of-quota customs duty raised from 25% to 50%. The deal also introduces a mandatory "country of melt and pour" declaratory requirement on steel imports and obliges the Commission to assess, within two years, whether the country of melt-and-pour should become the basis for country-specific TRQ allocations (closing transhipment loopholes that have allowed Chinese-melted steel to enter via third-country processors). The co-legislators added a reinforced and time-bound review mechanism: a first Commission review of product scope within six months of entry into force, with subsequent biennial scope reviews thereafter. Statutorily, this is a NEW instrument — a regulation adopted under the ordinary legislative procedure, not an implementing act under the WTO Agreement on Safeguards / Regulation (EU) 2015/478 — so it is filed as a new action with a `responds_to` link to the predecessor regime. Formal adoption by Council and EP plenary is expected in May 2026 ahead of the 1 July 2026 application date.

Government Resolution No. 350 of 31 March 2026 extended Russia's temporary ban on exports of liquid, granulated, and lump sulphur (HS 2503) through 30 June 2026. The measure was originally introduced by Resolution No. 1470 of 28 October 2025 (effective 1 November 2025) to stabilise raw-material supply for domestic mineral-fertiliser production, and had been successively extended through December 2025 and March 2026 before this latest extension. Exemptions apply to EAEU member states, Abkhazia, and South Ossetia; a concurrent GTA-recorded instrument (state-act 97135) converted certain lower-grade sulphur grades to a licensing regime rather than an outright ban.

Presidential Decree No. 193, signed by President Vladimir Putin on 25 March 2026 and in force from 1 May 2026, prohibits the export from Russia of refined gold bars (аффинированное золото в слитках) with a total weight exceeding 100 grams by individuals, legal entities, and individual entrepreneurs. Narrow exceptions apply for EAEU-destination and non-EAEU-destination movements through designated international airports (Vnukovo, Sheremetyevo, Domodedovo, and Knevichi/Vladivostok) conditional on Federal Assay Office or Federal Border Service permits. The stated rationale — curbing shadow-economy use of bullion as a foreign-currency substitute and closing capital-flight channels — is analytically inseparable from the broader post-2022 Russia counter-sanctions context and the G7 / LBMA delisting of Russian-origin gold.

The UK Finance Act 2026, which received Royal Assent on 18 March 2026, establishes the primary statutory framework for the United Kingdom Carbon Border Adjustment Mechanism (UK CBAM), granting HM Revenue & Customs the assessment, collection, and enforcement powers needed to apply a carbon-content levy on imports of aluminium, cement, fertilisers, hydrogen, and iron & steel from 1 January 2027. Two tranches of draft secondary legislation (the CBAM Regulations 2026 covering administration, rate calculation/carbon-price relief, emissions and verification, and transitory provisions) were published for technical consultation on 10 February 2026 (closing 24 March 2026) and again in Spring 2026 (closing 21 May 2026). The mechanism imposes a UK ETS-linked benchmark price on the embedded carbon of in-scope imports, with a credit for verified third-country carbon prices already paid, and — unlike the EU CBAM — has no transitional reporting phase and a narrower initial sectoral scope (no electricity).

Presidential Decreto 0264, signed on 16 March 2026 by President Gustavo Francisco Petro Urrego with Minister of Commerce Diana Marcela Morales Rojas and Minister of Finance Germán Ávila Plazas, sets a 35% MFN import duty on 14 steel and metal-mechanical subpartidas (bars, profiles, tubes, wire products, barbed wire) covering HS chapters 72-73 imported from countries with which Colombia has no free-trade agreement — primarily China, Russia, Turkey, and India. The measure is valid for one year from its entry into force (15 days after Diario Oficial publication on 16 March 2026), after which the Comité de Asuntos Aduaneros, Arancelario y de Comercio Exterior must review its impact. It partially amends Decreto 1881 de 2021 and operationalises the Política Nacional de Reindustrialización (CONPES 4129), the Petro administration's flagship programme to reduce Colombia's hydrocarbon dependence by building new domestic manufacturing capacity.

On 25 February 2026 the Swiss Federal Council adopted extensive amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (Ukraine Ordinance) and the Ordinance on Measures against Belarus, completing implementation of the EU's 19th sanctions package with effect from 26 February 2026. Headline measures: a complete ban on the purchase and import of Russian LNG taking effect 25 April 2026 (transition period until end-2026 for pre-existing long-term contracts); a complete prohibition on the provision of crypto-asset services to Russian persons and companies; new service bans covering advanced-technology / AI / high-performance-computing services and tourism-related services; expansion of the dual-use end-user list (Annex 2) including additional Chinese entities; SECO authority to grant divestment-exemption licences until end-2026 under Art. 30a; and parallel adoption of the EU October 2025 Belarus measures via amendment to the Belarus Ordinance.

President Trump signed Executive Order "Ending Certain Tariff Actions" on 20 February 2026 (Federal Register doc 2026-03832, published 25 February 2026), terminating the additional ad-valorem duties imposed under nine prior IEEPA-based executive orders. The order followed within hours of the US Supreme Court's 6-3 decision the same day in Learning Resources, Inc. v. Trump, 607 U.S. ___ (2026), holding that the International Emergency Economic Powers Act does not authorize the President to impose tariffs and vacating the Trump 2.0 IEEPA tariff regime. The EO directs CBP to cease collection "as soon as practicable"; CSMS guidance set the collection-end date at 12:00 a.m. eastern on 24 February 2026. The order explicitly preserves all underlying national-emergency declarations and all non-IEEPA trade actions — Section 232 of the Trade Expansion Act, Section 301 of the Trade Act, Section 122 of the Trade Act, and Section 201 — so the Section 232 cascade and the paired Section 122 10% temporary surcharge (effective 24 Feb 2026) remain in force. This is the first SCOTUS-driven repeal of a presidential tariff regime in the modern era and recalibrates the entire post-2024 US tariff architecture by removing IEEPA as a legal pillar.

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 29 January 2026 Switzerland's Federal Department of Economic Affairs, Education and Research (WBF) amended Annex 28 of the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), lowering the price cap on Russian seaborne crude oil from USD 47.6 to USD 44.1 per barrel, effective 1 February 2026. The amendment prohibits Swiss-domiciled operators from providing financial and transport (maritime, insurance, brokering) services related to Russian crude oil priced above the new cap. Switzerland is not an EU member but autonomously aligns its Ukraine Ordinance with EU sanctions packages; this cut mirrors the EU's Implementing Regulation 2026/124 and the UK OFSI general licence amendment adopted two weeks earlier under the same six-monthly dynamic-adjustment formula.

Regulation (EU) 2026/261 of the European Parliament and of the Council (adopted 26 January 2026, in force 3 February 2026) sets a legally binding stepwise ban on imports of Russian-origin natural gas — both liquefied (LNG) and pipeline. Russian LNG under short-term contracts signed before 17 June 2025 is prohibited from 25 April 2026; long-term LNG contracts from 1 January 2027. Russian pipeline gas under short-term contracts is prohibited from 17 June 2026; long-term pipeline gas from 30 September 2027 (latest 1 November 2027 if EU storage targets remain on track). The regulation operates outside the Russia-sanctions architecture (Article 215 TFEU) as a REPowerEU internal-market instrument, with narrow operational-amendment carve- outs and no provision for volume increases.

On 14 January 2026 the European Commission adopted Implementing Regulation (EU) 2026/124, amending Annex XXVIII to Council Regulation (EU) No 833/2014, lowering the price cap on seaborne Russian crude oil (CN code 2709 00) from USD 47.6 to USD 44.1 per barrel, effective 1 February 2026. This is the first application of the automatic dynamic-adjustment mechanism introduced by the 18th sanctions package (Council Regulation (EU) 2025/1494, July 2025), which re-indexes the cap every six months to 15% below the 22-week trailing average Urals market price. Contracts concluded before 31 January 2026 with cargo offloaded by 16 April 2026 remain subject to the prior USD 47.60/bbl cap. The UK aligned with an equivalent reduction the same day.

On 15 January 2026 the UK Office of Financial Sanctions Implementation (OFSI), acting under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, amended the 'Oil Price Cap' General Licence (INT/2024/4423849) to lower the price cap on Russian seaborne crude oil from USD 47.60 to USD 44.10 per barrel, effective 23:01 on 31 January 2026. Contracts signed at the prior USD 47.60 cap before that time are subject to a wind-down period, remaining valid provided the oil is offloaded at the port of destination by 22:59 on 16 April 2026. The cut applies the six-monthly dynamic-adjustment formula (15% below the 22-week trailing average Urals price) and was announced in lockstep with the EU's equivalent Implementing Regulation 2026/124.

Ukraine's President Volodymyr Zelenskyy signed Decree No. 8/2026 on 3 January 2026, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 95 individuals and 70 legal entities, the large majority of them Russian citizens, residents, and companies. The designees manufacture or supply communications equipment, radio-electronic warfare (REB) systems, and microelectronics for Russia's defense-industrial complex, alongside chemical, mining, metallurgical, and fuel-and-energy-sector entities and their managers. The decree entered into force on 6 January 2026, the date of official publication.

Presidential Decree No. 1011 of 31 December 2025 amends the standing Decree No. 302 (25 April 2023) list of foreign-owned assets under "temporary management," adding 100 percent of the shares in Rockwool LLC and 68 percent of the shares in Rockwool-Volga LLC — the Russian operating subsidiaries of Danish insulation producer ROCKWOOL A/S — and transferring control to Construction Assets Development JSC (Развитие Строительных Активов, "RSA"), a newly formed Russian administrator. The decree entered into force on its date of official publication (13 January 2026) despite being signed two weeks earlier, and covers four ROCKWOOL factories (Moscow, Leningrad and Chelyabinsk regions, and Tatarstan) producing heat and sound insulation. ROCKWOOL A/S disclosed in a 13 January 2026 regulatory announcement to Nasdaq Copenhagen that it has determined it has lost control of the four plants.

Presidential Decree No. 1012 of 31 December 2025 amends the standing Decree No. 302 (25 April 2023) list of foreign-owned assets under "temporary management," adding 100 percent of the shares in Can-Pak LLC (owned by Poland's Canpack S.A.) and Can-Pak Packaging Plant LLC (owned by Tapon France) — the two Russian operating subsidiaries of the CANPACK Group's aluminium-beverage-can business — and transferring control to StalElement LLC, a newly formed Russian administrator. The decree entered into force on its date of official publication (13 January 2026) despite being signed two weeks earlier, and covers Can-Pak's Volokolamsk (Moscow region) and Novocherkassk plants, which together hold an estimated 25-35% share of Russia's aluminium-can market. It is one of a running series of company-specific amendments to Decree 302, Russia's mechanism for placing Russian assets of "unfriendly state" companies under state administration in reciprocal response to Western sanctions and asset freezes.

Resolution of the Government of the Russian Federation No. 2089 of 22 December 2025 sets the tariff quota for the export of wheat, meslin, barley, and corn from Russia to countries outside the Eurasian Economic Union at 20 million tonnes, effective from 15 February to 30 June 2026. The quota for rye exports is set at zero tonnes. Within the quota, exports remain subject to Russia's floating in-quota grain export duty (formula-driven, indexed to global wheat reference prices); shipments outside the quota face a duty of 50% of customs value, but not less than €100 per tonne. Humanitarian-aid shipments authorised by separate government decisions are exempt. The H1 2026 cap roughly doubles the 10.6-Mt H1 2025 quota and is calibrated to a record 137-Mt 2025/26 Russian grain harvest.

Government Resolution No. 2076 of 19 December 2025 replaces Russia's standing ban on husked rice and rice-paddy exports (in force July 2022 – 31 December 2025) with a 200,000-tonne tariff-rate quota for calendar year 2026. Within the quota, exports to countries outside the Eurasian Economic Union face a 0% duty; shipments above the cap are charged 50% of customs value. The switch from an outright ban to a managed quota reflects Russia's view that domestic rice production now fully covers internal-market needs and that a quota-based mechanism can stimulate exports while preserving a price-stabilisation backstop.

The Council of the European Union adopted Regulation (EU) 2025/2618 on 18 December 2025, amending Regulation (EU) No 833/2014, to add 41 vessels to Annex XLII of the Russia sanctions regime. Of these, 36 vessels are designated for transporting Russian crude oil and petroleum products while engaging in irregular and high-risk shipping practices characteristic of the "shadow fleet," 5 vessels are designated for transporting stolen Ukrainian grain and cultural property, and 1 vessel (GT HONOR) is designated for facilitating violation or circumvention of EU sanctions. Listed vessels are banned from access to EU member-state ports and locks and from a broad range of maritime-transport-related services, effective 19 December 2025. The measure is an incremental listing update between the 19th (Regulation 2025/2033, October 2025) and 20th (Regulation 2026/506, April 2026) numbered sanctions packages, rather than a new package itself.

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.

The National Defense Authorization Act for Fiscal Year 2026 (P.L. 119-60), signed into law on 18 December 2025, expands the Department of Defense's existing "covered materials" domestic- sourcing restriction (which already barred DoD contracting for SmCo/NdFeB magnets, tantalum and tungsten sourced from China, Russia, Iran or North Korea) to add gallium, germanium and molybdenum under Section 844. Restrictions on materials "melted or produced" in a covered nation take effect 31 December 2026, widening on 1 January 2027 to also cover materials "mined, refined, or separated" in a covered nation; the gallium/germanium additions specifically phase in on 18 December 2027. The same NDAA bundles two related supply-chain provisions: Section 867 gives DoD broader authority (contracts, grants, other-transaction agreements, equity-style investments, and anti-market-manipulation subsidies) to invest in the domestic industrial base for critical minerals, microelectronics, machine tools and other defense-relevant capacity, and Section 842 bars DoD from procuring advanced batteries whose cells or key components are owned, sourced, refined or produced by a foreign entity of concern, phased in 2028-2031.

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 15 December 2025 the Government of the Russian Federation, via Order No. 3758-р signed by Prime Minister Mikhail Mishustin, allocated an additional RUB 60.58 billion (approx. USD 759 million) from the government's reserve fund to subsidise interest payments and provide financial grants to Russian credit organisations supporting preferential loans to agricultural producers. The allocation preserves preferential interest rates on roughly 48,000 previously issued loans, freeing working capital for producers to expand output of cereals, fruit and vegetables. It brings total 2025 federal subsidisation of the preferential agricultural credit programme to RUB 250.1 billion.

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.

Russia's Government adopted Resolution N° 1958 on 29 November 2025, amending Resolution N° 313 of 9 March 2022 to add eight commodity positions to Appendix 3 — the list of dual-use goods banned for export to "unfriendly" states. The added items are specialty electro-optical and semiconductor materials: lithium niobate, zinc telluride, gadolinium-gallium garnet, gallium arsenide, gallium phosphide, unprocessed and processed quartz wafers/plates, and polished tellurium-oxide prisms. These materials are inputs to electro-optical components (modulators, acousto-optic devices, IR/laser optics) with both civil and military (guidance, imaging) applications. The measure took effect 1 December 2025 and runs through the underlying ban's 31 December 2027 expiry; it applies to all countries except Eurasian Economic Union member states.

Ukraine's President signed Decree No. 870/2025 on 29 November 2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 26 Russian legal entities involved in crude petroleum and natural gas extraction, petroleum-product refining, and related energy-sector activity. The decree imposes asset freezes and bars commercial transactions and investment dealings with the designated entities. It entered into force on 2 December 2025, the date of official publication.

Russia's Government adopted Resolution N° 1947 on 28 November 2025, extending for a fourth consecutive six-month period the temporary ban on the export of waste and scrap of precious metals and of electrical and electronic equipment used principally for precious-metals recovery. The restriction runs from 1 December 2025 through 31 May 2026, covering waste and scrap of gold, silver, platinum, palladium, rhodium, iridium, osmium, and ruthenium, as well as metals plated or clad with precious metals. Carve-outs apply for cathode antimony ingots and small laboratory samples (≤500 g per batch) shipped by refineries for quality verification.

On 26 November 2025 Prime Minister Mark Carney announced a package of measures to protect Canada's steel and softwood lumber industries, effective 26 December 2025. For steel, Canada tightened the tariff-rate quota (TRQ) available to countries without a Canada free trade agreement from 50% to 20% of 2024 import levels, and cut the TRQ for FTA partners outside CUSMA (i.e. not the US/Mexico) from 100% to 75% of 2024 levels; imports above quota face a 50% surtax. A new 25% tariff on the full value of listed steel-derivative products (doors, windows, fasteners, structural components and related goods) applies to all countries, covering an estimated CAD 10 billion+ of derivative imports. For softwood lumber, Canada added CAD 500 million to the BDC Softwood Lumber Guarantee Program (bringing it to CAD 1.2 billion) and earmarked a further CAD 500 million under the Large Enterprise Tariff Loan facility for lumber-sector liquidity support.

Ukraine's President signed Decree No. 860/2025 on 25 November 2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 41 legal entities that collectively own 56 maritime vessels. The vessels are alleged to have made illegal port calls at Sevastopol and Feodosia — Ukrainian ports under temporary Russian occupation — to load and export stolen Ukrainian wheat, sunflower seeds, and other food commodities between 2022 and 2025. The sanctions (asset freezes, restrictions on commercial transactions and transit, and foreign- customer limitations) apply for a term of 10 years and entered into force on 27 November 2025, the date of official publication.

On 24 November 2025, OFAC assessed a civil monetary penalty of USD 4,677,552 — the statutory maximum and the largest single OFAC penalty ever imposed against an individual — against an Atlanta-based real-estate investor operating through King Holdings LLC. Between April 2023 and March 2024 the respondent willfully purchased, mortgaged, renovated, and resold US residential property beneficially owned by a family member of a Russian oligarch sanctioned under EO 14024, in direct violation of a prior OFAC cease-and-desist order and in defiance of an administrative subpoena. OFAC found the violations egregious and non-self-disclosed; both aggravating factors drove the penalty to the statutory ceiling.

Canada made SOR/2025-228, Regulations Amending the Special Economic Measures (Russia) Regulations, registered 2025-11-06 and announced by Minister Anand on 2025-11-12. The regulations add 13 individuals to Part 1 of Schedule 1, 11 entities to Part 2 of Schedule 1, and 100 vessels (by IMO number) to Schedule 1.1, freezing their Canadian assets and prohibiting dealings. Targets include Russian LNG-trading entities, drone-programme developers, cyber-infrastructure suppliers for hybrid operations against Ukraine, and Kyrgyzstan-based financial enablers (including Capital Bank of Central Asia and the A7 payments platform) used to evade earlier Russia sanctions. The 100-vessel designation targets Russia's "shadow fleet" used to move crude oil, LNG and arms while evading the G7 price cap and flag-state controls.

New Zealand's 33rd sanctions round under the Russia Sanctions Act 2022 designated 65 "shadow fleet" tanker vessels involved in transporting Russian-origin crude oil, together with seven entities and two individuals based in Russia, Belarus, North Korea and Iran that refine or transport Russian oil or facilitate oil-related payments. Designated parties are subject to asset freezes and prohibitions on the supply of services (including port access, insurance, chartering and cargo handling) by New Zealand persons. The measure targets the revenue chain funding Russia's war in Ukraine rather than imposing a new tariff or trade-flow control.

On 29 October 2025 the Swiss Federal Council amended the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), published as AS 2025 662, completing Switzerland's alignment with the remaining goods, finance and services elements of the EU's 18th Russia sanctions package (Council Regulation (EU) 2025/1494, 18 July 2025) and tightening the parallel Belarus regime. The amendment took effect 30 October 2025 and adds: an export ban covering additional structural-metal, general-purpose-machinery and machine-tool goods; an import ban on further petroleum-oil products and waste/scrap categories; and expanded controls on commercial transactions and investment instruments spanning financial services, investment banking, crude-petroleum trade and motor-vehicle/trailer goods. The Federal Department of Economic Affairs (WBF) had already taken over the measures within its own competence on 12 August 2025; this decision closes the remainder. In parallel, the Federal Council's asset-freeze annexes were extended to 14 individuals and 41 companies/organizations.

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 23 October 2025, the Council of the European Union adopted Council Regulation (EU) 2025/2041 (amending Regulation (EC) No 765/2006) and Council Decision (CFSP) 2025/2040 (amending Decision 2012/642/CFSP), widening the EU's Belarus restrictive-measures regime in lockstep with the 19th Russia sanctions package adopted the same day. The package widens the export ban to industrial goods (salts, ores, rubber articles, tyres, millstones, construction materials, electronic components, rangefinders, propellant chemicals, metals/oxides/alloys), extends the import ban to all acyclic hydrocarbons, introduces a new prior-licensing requirement for services supplied to Belarus, its government, or public bodies, and mirrors the Russia regime's space, AI, and high-performance/ quantum-computing service restrictions. A companion instrument, Council Implementing Regulation (EU) 2025/2039, adds 5 new asset-freeze listings (2 individuals + 3 entities, including JSC Holography Industry, Horizont Holding, and ICT Horizont). Entered into force 24 October 2025.

On October 22, 2025, the US Treasury's Office of Foreign Assets Control (OFAC) added Open Joint Stock Company Rosneft Oil Company ("Rosneft") and Lukoil OAO ("Lukoil") — together with dozens of named Russia-based subsidiaries — to the Specially Designated Nationals (SDN) List under Executive Order 14024 for "operating or having operated in the energy sector of the Russian Federation economy." It is the first US designation of Russia's two largest integrated oil majors since the 2022 invasion-era sanctions architecture began. Under OFAC's 50% Rule, the blocking extends automatically to all entities owned 50% or more, directly or indirectly, by Rosneft or Lukoil — capturing a sprawling global subsidiary network including Lukoil retail/refining assets in Belgium, Netherlands, Bulgaria, Romania, Italy, Finland, the West Qurna-2 upstream stake in Iraq, and Lukoil Americas. Rosneft and Lukoil together account for roughly half of Russian crude exports (~5 mb/d combined production) and Lukoil holds a ~9% European retail-fuel market share. OFAC simultaneously issued General License 124 (Caspian Pipeline Consortium / Tengizchevroil / Karachaganak Kazakhstan-pipeline carve-out, no expiry), General License 125 (Lukoil retail service stations outside Russia, wind-down to November 21, 2025), General License 126 (general wind-down to November 21, 2025) and General License 127 (debt/equity divestment and derivatives wind-down to November 21, 2025). GL 131 (issued November 14, 2025) opened a divestment window for Lukoil International GmbH; subsequent GL 134/134A/134B extended cargo-offload authorisations through April–May 2026. The action was coordinated same-day with UK OFSI Rosneft/Lukoil designations and the EU's 19th Russia sanctions package adopted October 23, 2025 — the first major US-led Russia-energy escalation under the second Trump administration.

On 15 October 2025 the UK Foreign, Commonwealth & Development Office, acting under the Russia (Sanctions) (EU Exit) Regulations 2019, designated 39 entities and specified 51 vessels — including, for the first time, Russia's two largest integrated oil majors PJSC Rosneft Oil Company and PJSC Oil Company Lukoil — for supporting Russia's energy, defence and financial sectors. 51 vessels (44 identified as "shadow fleet" tankers) were specified for transporting Russian crude oil and LNG in evasion of the G7 price cap. The package also introduced a ban on importing oil products refined in a third country from Russian-origin crude, closing a refined-product loophole in the price-cap regime.

Presidential Decree No. 710 of 6 October 2025 amends the standing list of foreign-owned assets under "temporary management" (established by Decree No. 302 of 25 April 2023) to add 100 percent of the shares in Vonorus LLC — the Russian operating subsidiary of Silgan Metal Packaging Mitterdorf GmbH, the Austrian unit of US-listed Silgan Holdings Inc. (NYSE: SLGN) — transferring control of the company to Rosimushchestvo. The decree entered into force on its date of official publication (6 October 2025) and is one of a running series of company-specific amendments to Decree 302, Russia's mechanism for placing Russian assets of "unfriendly state" companies under state administration in reciprocal response to Western sanctions and asset freezes.

Presidential Decree No. 693 of 30 September 2025 ("On certain particularities of the sale of property held in federal ownership"), signed by Vladimir Putin and entered into force on the day of its official publication, creates an accelerated pathway for disposing of federally-owned property in cases determined by a separate decision of the President, where the goal is to ensure the Russian Federation's defence capability and security. Market valuation and the appraisal report must be completed within 10 business days of signing the appraisal contract; PSB Bank JSC (formerly Promsvyazbank, the state-controlled defence-procurement bank) is designated as the sale-organising agent and seller-on-behalf-of-the-state. The Decree also authorises the President to set special features of how Russian legislation on privatisation, joint-stock companies, limited-liability companies, the securities market, banks and competition protection applies to such sales. Expressly framed as a counter-measure to "unfriendly" actions by the United States and its allies; structurally the disposal-mechanism complement to the foreign-asset external- administration and seizure decrees (95/322/520/442) — the fast-track liquidation channel that converts seized or nationalised assets into state-budget cash for defence purposes.

Russia's government imposed a temporary ban on exports of diesel fuel, marine (bunker) fuel and other gas oils (EAEU HS codes 2710 19 421 0 - 2710 19 429 0), including volumes purchased on exchange trading, effective 1 October 2025. The measure was framed as a domestic fuel-market stabilisation tool and initially exempted direct refinery producers from the ban. Russia is one of the world's largest diesel/gasoil exporters, so a full-coverage export halt on these grades has global gasoil-market significance, not just a regional effect. The ban has since been extended and tightened four times through mid-2026 (see amendments).

Japan's Ministry of Economy, Trade and Industry (METI) revised its Foreign End-User List (外国ユーザーリスト) — the reference list of foreign organisations for which WMD/missile or, for the first time, conventional-weapons development concerns cannot be excluded, used to trigger catch-all export-licence requirements. The revision adds 92 entities (from China, Hong Kong, North Korea, Russia, Pakistan, Iran and the UAE) and removes 5 entities (from China, Iran and India), taking the list to 835 entities across 15 countries and regions — a net increase of 87. The revised list applies from 9 October 2025, the same date Japan's broader catch-all conventional-weapons supplementary export-control review took effect.