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

Germany's Federal Economic Affairs Ministry (Bundesregierung) and BAFA issued Allgemeine Genehmigung Nr. 48 (AGG 48) on 20 March 2026, a time-limited general export licence simplifying the export of specified air-defence and maritime-defence equipment to Bahrain, Qatar, Kuwait, Oman, Saudi Arabia, the United Arab Emirates, and Ukraine, in force until 15 September 2026. Exporters may register retrospectively up to 30 days after first shipment, replacing individual-licence applications for in-scope items and materially compressing per-shipment administrative lead times. The measure is framed as part of Germany's reinforced commitment to supplying defence equipment to allies countering regional threats and Russian aggression.

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.

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.

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.

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.

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.

On 16 August 2025, Ukraine's President signed Decree No. 599/2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 39 individuals and 55 legal entities identified as involved in developing, manufacturing, or supplying components for Russian unmanned aerial vehicles (UAVs) with artificial-intelligence elements. The list covers 43 Russian entities (including drone makers Prognatik, Rozumni Ptakhy, Zala Aero, and KB Vostok, plus AI research centres Neurolab and TsBST), 10 Chinese suppliers of navigation receivers, engines, cameras, and microchips (including Dongguan Standard Trading, Zhejiang Lianxing Machinery, Shenzhen Sky Bow Navigation Technology, and Topscom Precision Industry), and 2 Belarusian component suppliers. Sanctions impose asset freezes and restrictions on commercial transactions and investment instruments, entered into force immediately upon signature and revocable no later than 15 August 2035.

On 8 August 2025, Ukraine's President signed Decree No. 595/2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against Russian state nuclear corporation Rosatom and its international corporate network. Sanctions were applied to 18 individuals and 17 legal entities identified as involved in attempts to integrate the occupied Zaporizhzhia Nuclear Power Plant into Russia's grid, participation in the seizure of the Chornobyl NPP, production and servicing of dual-use nuclear equipment, and export of enriched uranium through Rosatom subsidiaries registered in Switzerland, Cyprus, the Netherlands, and Finland. Named entities include Uranium One Holding N.V. (Netherlands), Rosatom Finance Ltd (Cyprus), and JSC Kirov-Energomash (Russia).

On 14 July 2025, the Cabinet of Ministers of Ukraine adopted Resolution No. 845 "On the approval of the lists of minerals and components of strategic and critical importance, and the lists of subsoil areas (mineral deposits) of strategic and/or critical importance," establishing Ukraine's first national taxonomy for critical-minerals governance: 11 strategic minerals (incl. uranium, titanium, zirconium, copper, nickel, tantalum, strontium, niobium, beryllium, aluminium, fluorite) and 28 critical minerals (incl. lithium, rare earths, vanadium, gallium, indium, caesium, tin). The resolution simultaneously designates 60 subsoil-area blocks for electronic auction of special permits for subsoil use and 26 deposits for competitive tender under Production Sharing Agreements, operationalising Chapter 13 (Critical Raw Materials Management) of Ukraine's Plan under the Ukraine Facility (Resolution No. 244-p of 18 March 2024) and providing the domestic licensing scaffolding through which obligations under the 30 April 2025 US-Ukraine Mineral Resources Agreement and EU Critical Raw Materials Act strategic-partnership track will flow.

On 8 May 2025 the Verkhovna Rada ratified the 30 April 2025 Washington intergovernmental agreement establishing the U.S.-Ukraine Reconstruction Investment Fund (draft law 0309, 338 of 450 MPs in favour); President Zelenskyy signed the ratification law on 12 May 2025. On 4 June 2025 the Rada then adopted in second reading and as a whole the implementing amendments to the Budget Code of Ukraine (draft law 13256, 309 MPs in favour), which credit half of royalties from new licences for the extraction of minerals of national importance (per Annex A of Cabinet Resolution 845) and half of state share revenues under new production-sharing agreements to a State Budget special fund earmarked for transfer to the joint Fund. The Fund is jointly managed 50/50 by the US International Development Finance Corporation (DFC) and a Ukrainian state entity, gives the US first-look preferential access to new lithium, titanium, REE, graphite, uranium and oil-and-gas projects, and is the structural anchor of the 2025 US critical-minerals pivot away from China.

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).

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 Bureau of Industry and Security (BIS) issued a final rule (FR Doc 2024-08622; Docket 240417-0112; 89 FR 30119) amending the Export Administration Regulations (EAR) to expand the product scope of two Foreign Direct Product (FDP) rules — the Iran FDP rule and the Russia/Belarus/Temporarily occupied Crimea region of Ukraine FDP rule in 15 CFR 734.9(f) — to cover the entirety of the Common High Priority List (CHPL), an HTS-6 list developed jointly with the EU, Japan and the UK that identifies items used in Russian weapons production. The CHPL scope adds basic commercial-grade microelectronics (integrated circuits, RF transceiver modules), test/manufacturing equipment for electronic components, and CNC machine tools to the perimeter, requiring a BIS licence when these foreign-produced items are exported, reexported or transferred to Iran, Russia, Belarus or occupied Crimea. The rule was issued in response to Iran's 13 April 2024 attack on Israel and Iran's ongoing military support for the Russian war in Ukraine; it became effective 18 April 2024 (Federal Register publication 22 April 2024) with a transit grace period for in-flight shipments until 20 May 2024.

President Volodymyr Zelenskyy signed Decree No. 31/2024 on 26 January 2024, establishing the All-Ukrainian Economic Platform "Made in Ukraine" (Зроблено в Україні) as the foundational legal architecture for Ukraine's wartime domestic-industrial-development programme. The decree creates a coordinating body under the President — an advisory council convening the Cabinet of Ministers, Ministry of Economy, Ukrainian Chamber of Commerce and Industry, and State Property Fund — mandated to implement public-procurement preferential margins for Ukrainian-origin goods, administer the eRobota state-grants programme (~UAH 35 bn/year), and establish the National Cashback programme rewarding consumers for purchasing domestic goods via the Diia state-digital platform. The instrument is the statutory parent for the cluster of wartime localisation and industrial-preference measures operationalised through subsequent Cabinet Resolutions and Verkhovna Rada legislation.

Resolution No. 1466 of 27 December 2022 approves, for 2023, the volume of export quotas for licensed goods (Annex 1), the controlled ozone-depleting substances and fluorinated gases whose export and import require a licence (Annexes 2-3), and a list of goods whose export requires a licence (Annex 5). Annex 1 sets a zero quota for hard coal and anthracite, wood fuel, natural gas of Ukrainian origin, unwrought gold and silver and precious-metal scrap, and finite quotas of 900,000 t for coking coal and 540,000 t for fuel oil. The resolution took effect on 1 January 2023 and was amended repeatedly during 2023.

Council Regulation (EU) 2022/1903 amends Regulation (EU) 2022/263 so that its import ban and export restrictions, previously limited to the non-government-controlled areas of Donetsk and Luhansk, also cover the non-government-controlled areas of Ukraine's Kherson and Zaporizhzhia oblasts. It was adopted on 6 October 2022 alongside the eighth Russia sanctions package and entered into force the day after publication in the Official Journal.

The Bureau of Industry and Security added 57 entities under 57 entries to the Entity List, effective September 30, 2022, in direct response to Russia's ongoing invasion of Ukraine and its illegal annexation of Ukrainian regions. Of the 57 entities, 56 are listed under Russia and one (Subsidiary Sevastopol Naval Plant of Zvezdochka Shipyard) under the Crimea Region of Ukraine. The additions span aviation repair and overhaul facilities, aerospace R&D institutes, naval propulsion, ballistic-missile producers, advanced-materials and quantum science institutes, and the federal metrology agency; 50 of the 57 receive footnote 3 designations as Russian military end users, subjecting them to the Russia/Belarus-Military End User Foreign Direct Product Rule. All are added with a license review policy of denial for all EAR-subject items except food and medicine designated EAR99.

On 28 February 2022 the Swiss Federal Council decided to adopt the EU sanctions packages of 23 and 25 February 2022. As part of this, the import, export and investment ban in place for Crimea and Sevastopol since 2014 was extended to the Ukrainian regions of Donetsk and Luhansk that are not under Ukrainian government control. The Federal Council instructed the EAER to amend the existing ordinance in line with the EU measures.

SOR/2022-28, registered and in force on 24 February 2022, amends the Special Economic Measures (Ukraine) Regulations to prohibit persons in Canada and Canadians abroad from making investments involving property in the so-called Donetsk People's Republic and Luhansk People's Republic regions, from importing, purchasing or acquiring goods from them, and from exporting goods destined for them. It also bars related financial services, technical assistance and tourism-related services. The prohibitions are territorial and apply to goods generally; no product list is itemised.

On 24 February 2022 Japan's Foreign Minister announced sanctions following Russia's recognition of the "Donetsk People's Republic" and "Luhansk People's Republic". Japan suspended visa issuance to and froze assets in Japan of individuals of the two "Republics", prohibited imports from and exports to the two regions, and prohibited the issuance of and transactions in new Russian sovereign debt in primary and secondary markets. The relevant ministries were to proceed with the domestic procedures needed to implement them.

Effective 24 February 2022 — the date of Russia's full-scale invasion of Ukraine — the US Bureau of Industry and Security (BIS) published an interim final rule (87 FR 12226, FR Doc 2022-04300) adding sweeping new export license requirements under a new § 746.8 of the Export Administration Regulations (EAR). The rule requires a licence for any item in CCL Categories 3–9 (electronics, computers, telecommunications, sensors, lasers, navigation/avionics, marine, aerospace, propulsion) exported, reexported, or transferred to Russia, with a review policy of denial. Two new Russia-specific Foreign Direct Product (FDP) rules extend US jurisdiction to foreign-manufactured goods: the Russia FDP Rule (§ 734.9(f)) covers all foreign-made items using US technology/equipment destined for Russia, and the Russia-MEU FDP Rule (§ 734.9(g)) covers items destined to 47 designated military-end-user (MEU) entities with no licence exceptions available. All three restrictions carry a presumption of denial, making this the most sweeping peacetime expansion of the EAR since its modern codification.

The Autonomous Sanctions Amendment (Ukraine Regions) Regulations 2022 (F2022L00179) apply to the Ukrainian regions of Donetsk and Luhansk the autonomous sanctions measures already in place for Crimea and Sevastopol, commencing 28 March 2022. DFAT describes the measures as prohibiting trade in the transport, energy, telecommunications, and oil, gas and minerals sectors of those regions. Foreign Minister Marise Payne announced Australia's response on 24 February 2022, alongside listings of Russian individuals and banks.

Council Regulation (EU) 2022/263 prohibits importing into the EU any goods originating in the non-government-controlled areas of Ukraine's Donetsk and Luhansk oblasts, and bans the sale, supply, transfer or export of Annex II goods and technology (transport, telecommunications, energy, resource extraction) to those areas. It also bars new investment and financing there. It entered into force the day after adoption, 24 February 2022.

Executive Order 14065, signed 21 February 2022, prohibits new investment by US persons in the so-called Donetsk and Luhansk People's Republic (DNR/LNR) regions of Ukraine, bans the importation into the United States of any goods, services or technology from those Covered Regions, and bans exports, reexports, sales or supply to them by or from US persons. It also prohibits US-person approval, financing, facilitation or guarantee of transactions by foreign persons that would be barred if done by a US person. It expands the national emergency first declared in EO 13660.