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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.
The Bureau of Industry and Security published a temporary final rule (91 FR 60505, RIN 0694-AK57) implementing the anti-stockpiling directive of Proclamation 11052 (6 August 2026), which sets Section 232 minimum import prices and tariffs on polysilicon and derivatives from 4 December 2026. The rule, effective 22 September through 3 December 2026, lets Commerce bar importers of record that import volumes substantially above their historic averages, caps weekly volumes of importers registered with CBP on or after 6 August 2026, and sets a waiver process.
On 18 September 2026 the President signed a proclamation extending Proclamation 10973 (originally issued 19 September 2025), which conditions issuance/entry on new H-1B specialty-occupation petitions on a $100,000 payment by the sponsoring employer, for a further 12 months through 21 September 2027 (exceptions remain at DHS Secretary discretion for national-interest cases). Alongside it the President signed a companion executive order, "Enhancing Program Integrity and Interagency Coordination in the Administration of the H-1B Nonimmigrant Visa Program," directing DHS, State and Labor to coordinate review of H-1B petitions and consult Commerce, Education and SBA on employment data, with heightened scrutiny for employers with recent or planned US-worker layoffs. The accompanying fact sheet cites a 92% drop in H-1B registrations by the largest IT-outsourcing firms (24,946 to 2,055) and a ~97% decrease in consular H-1B processing requests since the original 2025 proclamation. ## Severity basis Quant anchor from the primary source: $100,000 flat fee per covered H-1B petition, extended for a further 12-month term (through 2027-09-21); a measured 92% reduction in H-1B registrations by the largest IT-outsourcing filers (24,946 → 2,055) and a ~97% drop in consular H-1B processing requests attributed to the fee regime since its 2025 introduction. Severity 4/5: a binding, renewed cost barrier with a demonstrated order-of-magnitude effect on offshore-staffing-dependent filers, not a one-off or symbolic measure.
President Trump signed H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, into law on 18 September 2026, after the House concurred in Senate amendments on 16 September 2026 (262-159) and the Senate passed it on 7 August 2026 (86-11). The Act authorizes a 500% tariff on all US imports of Russian-origin goods and up to 100% tariffs on the top five importers of Russian oil and gas and the top five countries supporting Russia's oil "shadow fleet," alongside sanctions on Russian banks, the Russian financial system, and shadow-fleet vessels. It also extends the Iran Sanctions Act through 2031. All tariff/sanctions authority is discretionary: the President may decline to impose it by certifying to Congress that doing so serves the national interest, and may terminate it if Russia agrees to a durable peace with Ukraine. The Act sunsets five years after enactment.
The US Department of Commerce issued a preliminary affirmative determination (case A-570-228) that tin mill products from China are being sold in the US at less than fair value, finding a China-wide dumping margin of 136.52% based on adverse facts available (no Chinese producer/exporter responded to the investigation), adjusted to a 130.17% cash deposit rate after offsetting the parallel countervailing-duty determination. Commerce also made a preliminary affirmative finding of critical circumstances, extending provisional measures and cash-deposit collection retroactively. The investigation was petitioned by United States Steel Corporation and the United Steelworkers union; final determinations are scheduled for around 1 December 2026.
OFAC added four Cuban state-owned nickel-sector enterprises to the SDN List under Executive Order 14404 — Centro de Investigaciones del Níquel (CEDINIQ), Empresa de Ingeniería y Proyectos del Níquel (CEPRONIQUEL), a technical/computing services entity (SERCONI), and Pinares S.A. — alongside three individual Cuban-national designations and a parallel round of military-modernization-linked designations. The action, publicised as "Further Sanctions on Cuba's Mineral Wealth and Military Modernization Apparatus," blocks all US-person transactions and freezes US-touching assets of the named entities, targeting the research, engineering and technical-services layer behind Cuba's nickel extraction and processing industry.
The US Department of Commerce issued a preliminary affirmative countervailing duty determination (case C-570-229) finding that producers/exporters of tin mill products from China received countervailable subsidies at a rate of 66.61% ad valorem, applied both to the individually-examined respondents (Shougang Holding Trade (Hong Kong) Ltd. and Shougang Jingtang United Iron & Steel Co. Ltd.) and to the all-others rate, based on facts available with adverse inferences after non-cooperation. Commerce also made a preliminary affirmative finding of critical circumstances, and directed CBP to suspend liquidation and collect cash deposits on entries from the date of publication. The final CVD determination is aligned to issue alongside the companion antidumping determination, currently scheduled no later than 2026-11-30.
On September 14, 2026, the US Treasury's Office of Foreign Assets Control designated VTB Bank Public Joint Stock Company under Executive Order 13902 (Iran financial-sector sanctions), citing correspondent banking relationships VTB built with sanctioned Iranian financial institutions and settlement systems VTB created for bilateral rial/ruble trade that Treasury says moved frozen Iranian assets. VTB was already designated under EO 13662 (2025) and EO 14024 (2022) for Russia-related conduct; this action adds an Iran-sanctions legal basis and SDN listing, part of the broader "Operation Economic Outcast" campaign Secretary Bessent announced August 24, 2026. No specific dollar figure for the moved assets was disclosed.
On 9 September 2026 President Trump signed five proclamations under Section 338 of the Tariff Act of 1930 responding to Canada's 8 September 2026 retaliatory tariffs on roughly $20bn of US exports (steel, dairy, agricultural equipment). The proclamations impose outright import bans on certain Canadian alcoholic-beverage and dairy products that had been subject to the 50% Section 338 duties imposed 22 August 2026 (following Canada's continued discrimination against US alcohol and dairy commerce), and separately exclude certain Canadian motor-vehicle-sector products from importation for the same reason. The proclamations also modify the product scope of the July 20, 2026 Section 338 tariff actions, removing items such as rock salt and cement and adding others, including all-terrain vehicles and additional dairy products. The import bans take effect 29 September 2026; the product-list modifications take effect 15 September 2026. The duties/bans apply regardless of USMCA origin and stack on top of Section 232 tariffs.
On September 4, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated Istanbul-based Golden Global Yatirim Bankasi Anonim Sirketi (Golden Global Bank) and two affiliates — Golden Global Portfoy Yonetimi Anonim Sirketi and Golden Global Varlik Kiralama Anonim Sirketi — to the Specially Designated Nationals (SDN) List under Iran sanctions authorities. Treasury said the bank facilitated tens of millions of dollars in transactions for the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), giving the Iranian regime correspondent banking access to move funds internationally through the Turkish financial system. OFAC concurrently issued Iran General License CC, authorizing a wind-down of transactions involving the newly blocked persons. The Federal Register formally published GL CC — alongside GL DD, a separate Iran civil-aviation wind-down license issued September 8 — on September 11, 2026.
Following concurrent first five-year ("sunset") reviews, the US Department of Commerce and USITC determined that revoking the antidumping duty orders on silicon metal from Bosnia and Herzegovina, Iceland and Malaysia, and the countervailing duty order on silicon metal from Kazakhstan, would likely lead to continuation or recurrence of dumping, countervailable subsidies and material injury to the US industry. Commerce published continuation of all four orders effective 2026-09-03, so US Customs and Border Protection keeps collecting AD/CVD cash deposits at the existing rates — Kazakhstan's 120.00% economy-wide CVD rate, Bosnia and Herzegovina's 21.41% AD rate, Iceland's 37.83%-47.54% AD range, and Malaysia's 12.27% final AD rate — for a further five years absent a subsequent review.
On September 2, 2026, OFAC amended its Venezuela minerals-sector general licenses to bring coal within their scope and to name a second Venezuelan state-owned company, Carbones del Zulia S.A. ("Carbozulia"), alongside the existing mining SOE CVG Compañía General de Minería de Venezuela C.A. ("Minerven"). GL 51D (supersedes 51C, dated August 27, 2026) authorizes export, sale, purchase and transport of Venezuelan-origin coal or minerals, including gold; GL 54C (supersedes 54B) authorizes supply of goods, technology and services to coal-or-minerals operations; and new GL 55A authorizes negotiating and entering contingent contracts (bids, MOUs, agreements in principle) for coal-or-minerals investment, each contract conditioned on separate OFAC authorization before execution. OFAC also amended FAQ 1247. All three licenses remain conditioned on US/UK/France/Singapore dispute-resolution forum selection, routing of blocked-person payments into the Foreign Government Deposit Funds established by Executive Order 14373, and continue to exclude Russia-, Iran-, North Korea-, Cuba- and China-linked counterparties.
President Trump signed Executive Order 14420 on 26 August 2026, declaring a national emergency under IEEPA and the National Emergencies Act over foreign threats to the US bulk-power system. The order generally prohibits the acquisition, import, transfer, or installation of foreign-produced bulk-power system electric equipment — transformers, inverters, battery storage, generators, circuit breakers, turbines, and industrial control systems, including associated software and remote-access capabilities — where a transaction involves a "Covered Foreign Entity" and poses a risk of sabotage, unauthorized access, or catastrophic disruption to critical infrastructure. Local electric distribution facilities are excluded. No countries or companies are named in the order itself; DOE must publish implementing rules within 120 days (by 24 December 2026) identifying covered equipment and entities, and submit recommended Federal Acquisition Regulation revisions within 180 days.
Canada's Department of Finance published an updated list of over 700 US-origin products subject to counter-tariffs effective 2026-09-08, covering CA$27.6 billion of US imports across steel, aluminium, dairy, appliances, agricultural equipment, pulp/paper and electronics. Rates (15%, 25% or 50% depending on product) are matched dollar-for-dollar to the corresponding US Section 338/232 tariffs on the same goods, explicitly countering the United States' 22 August 2026 decision to impose a 50% tariff on CA$27.6 billion of Canadian goods. Steel and aluminium flat-rolled products carry the top 50% counter-rate.
On 24 August 2026, the Director of OFAC, in consultation with the Department of State and pursuant to 31 CFR 560.802, determined that section 1(a)(i) of Executive Order 13902 shall apply to the aviation, digital asset, gold, shipping, and technology sectors of the Iranian economy, effective the same day and formally published in the Federal Register on 27 August 2026 (FR Doc 2026-17487). The determination — part of a Treasury campaign publicly branded "Operation Economic Outcast" — exposes any person operating in, or knowingly engaging in a significant transaction for the sale, supply, or transfer of significant goods or services to or from, these five sectors to secondary-sanctions and SDN-listing risk under E.O. 13902, and extends potential correspondent/ payable-through account restrictions to foreign financial institutions that knowingly facilitate such transactions. OFAC did not publish sector definitions and concurrently suspended several general licenses covering educational exchange, personal remittance, conference, and academic/ sports-exchange activity with Iran (administered separately via GL AA and GL BB, wind-down through 8 September 2026).
President Trump signed a Section 232 proclamation on 13 August 2026 (published in the Federal Register 19 August 2026, FR doc 2026-16979) imposing tariffs on unmanned aircraft systems (UAS/drones) and components, following a Commerce Department finding that US reliance on foreign-produced (chiefly Chinese, e.g. DJI/Autel) drones and critical components creates supply-chain and cybersecurity national- security risk. A 100% ad valorem tariff applies to Annex I items (drones with maximum takeoff weight over 25kg, thermal-imaging drones, docking stations, and listed critical components); a 25% ad valorem tariff applies to Annex II items (other listed UAS). Qualifying-origin content from the EU, Japan, Korea, Switzerland, Taiwan and Liechtenstein is capped at 15%; UK-origin content is capped at 10%. UAS duties take effect 3 September 2026; component duties take effect 9 February 2027. The proclamation also authorizes Commerce to set up an onshoring program giving temporary relief to firms committing to build or expand US production of covered drones and components.
The White House announced over $2 billion in direct federal investment across eight critical-minerals and battery-material companies, funded through the Department of War (formerly DOD), the Export-Import Bank, and the Development Finance Corporation. The largest awards are $1.4 billion to Sila Nanotechnologies for silicon-carbon battery anodes and lithium-ion cell manufacturing, $400 million to Sunrise Energy Metals for a scandium value chain, and $150 million to Niron Magnetics for rare-earth-free permanent magnet production in Minnesota. An additional $180 million was committed to mining-workforce education across 17 schools.
BIS published a temporary final rule under DPA section 101 (following a Presidential Determination dated July 30, 2026 that recoverable critical minerals and materials are scarce and essential to national defense) requiring U.S. persons to allocate 100 percent of their monthly sales of black mass (shredded lithium-ion battery scrap containing lithium, cobalt, nickel, manganese and graphite) and tungsten waste and scrap to other U.S. persons, effectively barring export of these materials without an explicit BIS adjustment or exception. The order takes effect August 27, 2026, runs for one year through August 27, 2027, and BIS is accepting public comments through November 4, 2026 on whether additional sales requirements are needed. This is the first US DPA/export-control action targeting the recycling and secondary-materials stage of the critical minerals supply chain, rather than primary mining or refining.
China's Ministry of Commerce announced that drones, key drone components, and related technologies already listed on China's Dual-Use Items Export Control List will be subject to strict case-by-case review when exported to the United States, and will no longer be eligible for licensing-facilitation measures. The measure does not add new items to the control list or ban exports outright — it tightens the review standard and removes expedited-licensing treatment for existing listed drone items. MOFCOM said the move is a countermeasure responding to recent US actions, including the FCC's ban on imports of Chinese drones and DHS's addition of 43 Chinese companies to the Uyghur Forced Labor Prevention Act entity list.
China's Ministry of Commerce issued Order No. 2 [2026] on 5 August 2026, imposing countermeasures under Articles 3, 4, 6, 9, 10 and 15 of the Anti-Foreign Sanctions Law against six US entities — Applied DNA Sciences, Stratum Reservoir, Altana Technologies, the Responsible Business Alliance, Verite Group, and Human Rights in China — for "assisting and supporting" US sanctions and restrictions targeting Xinjiang. The order prohibits organizations and individuals within China from conducting transactions or cooperation with the six named entities, effective immediately. The stated trigger is Washington's prior import ban on products from 43 Chinese companies over alleged Xinjiang forced-labor practices.
President Trump signed Executive Order 14415 on 20 July 2026, tightening the 10 U.S.C. 4872(c)(1) "specialty metals" waiver process for defense contractors: from 1 January 2027, waivers will be granted only under approved mitigation plans showing "exhaustive efforts" to source compliant materials and a documented timeline for removing non-compliant content. The order requires the Secretary of War to develop, within 180 days, a supply-chain mapping policy compelling contractors to trace covered materials to raw-material origin ("indentured Bill of Materials"), with final implementing regulations due 90 days after that, and a source-qualification acceleration strategy for domestic and allied alternatives to "unreliable foreign suppliers" due within 90 days. Mandatory progress reporting runs at 6-month intervals through 1 January 2028. The order explicitly preserves the U.S. Strategic Critical Minerals Reserve ("Project Vault") and Export-Import Bank-financed or government-backed sourcing arrangements from its restrictions.
BIS published a final rule removing the UAE from Export Administration Regulations Country Groups D:3 and D:4 and adding it to Country Group A:5 — the tier reserved for the closest US allies. The change unlocks License Exception STA (military items, commercial satellites/spacecraft, and dual-use goods for oil/gas, desalination and civil nuclear power) plus several other license exceptions, and grants the UAE government and BIS-preapproved entities (currently G42 and Core42 only, per Supplement No. 8) license-free export of advanced computing items. Preapproved private entities have a 270-day window to become majority US-owned or lose automatic eligibility; other private UAE entities must still petition BIS case-by-case.
On 29 June 2026 the US President declared an emergency under Section 318(a) of the Tariff Act of 1930 (19 U.S.C. 1318(a)) over "threats to the availability of sufficient supplies of fertilizers to meet expected agricultural demand" and suspended collection of duties and estimated-duty deposits under 19 U.S.C. §§1671, 1675 and 1677j — the countervailing and antidumping statutes — on phosphate fertilizer imports from Morocco. The suspension runs for the earlier of eight months from the proclamation date or termination of the emergency, and effectively lifts the AD/CVD wall (already reduced to a 2.11% CVD rate by a December 2025 Court of International Trade remand in the OCP case) on Moroccan phosphate imports. Morocco (OCP Group) holds roughly 70% of world phosphate-rock reserves and is the single largest external phosphate-fertilizer source into the US farm supply chain.
China's Ministry of Commerce issued Announcement No. 23 of 2026 on June 22, 2026, adding 10 US entities to the Export Control Management List under the Export Control Law and Dual-Use Items Export Control Regulations. The listing prohibits Chinese exporters from supplying dual-use items to these entities and bars any global party from transferring China-origin dual-use goods to them; ongoing transactions are suspended pending MOFCOM approval. The 10 entities include the two largest non-Chinese rare earth producers — MP Materials Corp. (Mountain Pass, CA) and USA Rare Earth Inc. (Round Top, TX) — as well as eight US defence firms (Aveox, Red Cat Holdings, Teal Drones, IMSAR, Jaia Robotics, Ball Aerospace, Oshkosh Defense, L3Harris Maritime). MOFCOM explicitly framed the action as retaliation for the US DoD's June 8, 2026 update to the Section 1260H Chinese Military Companies list, which added ~80 Chinese parent firms and 188 affiliates.
Executive Order 14413, signed 22 June 2026, directs a national quantum-computing industrial-policy push: the QC-ADDS effort to deliver large-scale quantum computers to Department of Energy facilities for application development and discovery science, a National Center for Quantum Computing Assessment, an expanded Quantum Information Science and Technology Counterintelligence Protection Team, and a network of National QIST Workforce Development Institutes. It sets staged deadlines (30/60/90/120/180 days) for agency policy alignment, sensor-project identification, QC-ADDS technical specifications, and workforce/supply-chain plans, plus a September 2028 target for next-generation quantum-sensor deployment. Section 9 directs harmonisation of research-security and export-control policy with allies to prevent "countries of concern" from acquiring critical quantum technologies, but the order does not itself impose any new export-control rule. No dollar figures are specified.
On June 21, 2026, OFAC issued Iran-related General License X (GL X), authorizing transactions otherwise prohibited under the Iranian Transactions and Sanctions Regulations (31 CFR part 560), the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587), the Ukraine-/Russia-Related Sanctions Regulations (31 CFR part 589), and WMD-proliferation sanctions authorities — including new purchases and loadings of Iranian-origin crude oil, petrochemical, and petroleum products, a materially broader carve-out than the cargo-already-loaded window granted by the preceding General License U. Just 16 days later, on July 7, 2026, OFAC issued General License X1, revoking and superseding GL X: as of that date new purchases or loadings of Iranian-origin crude oil, petrochemical, or petroleum products were no longer authorized. GL X1 itself subsequently expired. OFAC formally published both web licenses in the Federal Register on September 30, 2026 — a retrospective publication of licenses already issued and, by then, already revoked and expired.
On June 17, 2026, BIS announced a $36,184,680 civil penalty settlement with Robert Bosch GmbH (Stuttgart, Germany) — the largest-ever BIS enforcement penalty against a non-US company for Foreign Direct Product Rule (FDPR) violations. Between September 16, 2020 and September 26, 2024, Bosch exported approximately $72.4 million in MEMS sensor products and automotive software from abroad to Huawei Technologies and its Entity List affiliates without the required BIS license. Bosch filed a Voluntary Self-Disclosure and cooperated throughout; the DOJ issued the first-ever NSD declination under its newly established Corporate Enforcement Policy, declining criminal prosecution entirely.
On June 8, 2026, the US Department of Defense published its annual update to the Section 1260H Chinese Military Companies (CMIC) list, adding 65 entities (17 new parent companies and 48 subsidiaries), bringing the total to approximately 188–200 designated entities. Major additions span EV and battery manufacturing (BYD, NIO, CATL), consumer internet (Alibaba, Baidu, Tencent), semiconductors (SMIC, YMTC, CXMT), solar (JA Solar, Trina Solar), biotech (BGI Genomics, WuXi AppTec), drones/robotics (DJI, Unitree, RoboSense), and telecoms (TP-Link). Effective June 30, 2026, DoD is prohibited from procuring goods, services, or technology directly from listed entities; effective June 30, 2027, the ban extends to indirect supply-chain procurement through prime contractors and all sub-tiers.
On 4 June 2026 USTR published a formal Notice of Determination in the Federal Register (doc 2026-11158, docket USTR-2025-0043) concluding that Brazil's acts, policies, and practices in six areas — digital trade and electronic payment services, unfair preferential tariffs, anti-corruption enforcement, IP protection, ethanol market access, and illegal deforestation — are unreasonable and burden US commerce. Simultaneously, USTR proposed a 25% ad valorem tariff on all Brazilian-origin goods, subject to ~1,600 HTS subheading exclusions including approximately 430 civil-aircraft lines. A public hearing is scheduled for 6 July 2026 and USTR faces a statutory deadline of 15 July 2026 to finalise any responsive action; the tariff has not yet taken effect.
President Trump signed an Executive Order on June 3, 2026 restructuring the entire US customs-entry compliance architecture for global importers. Key provisions impose heightened bonding minimums and domestic-asset requirements for foreign importers of record (IORs), require CAATSA-compliance and supply-chain-disclosure certifications, restrict foreign IORs to formal entry only (creating a de facto US-IOR monopoly on informal entry), establish a "good standing" requirement for IOR eligibility, and sharply curtail CBP's mitigation authority while setting enhanced penalty floors. DHS/CBP is directed to implement penalty-floor, export-documentation, and disposal provisions within 90 days (~September 2026) and the IOR structural reforms within 180 days (~November 2026). The EO is structurally distinct from tariff-rate instruments (Section 232 Proclamations 11021/11032), trade-remedy channels (USTR Section 301), statutory forced-labor enforcement (UFLPA), and targeted-sanctions channels (BIS/OFAC) — it reshapes the foundational compliance architecture through which all goods enter the US market.
On June 3, 2026, USTR formally initiated a Section 301 investigation (FR Doc. 2026-11043) into Vietnam's acts, policies, and practices relating to intellectual property protection and enforcement. This is the first Vietnam-specific Section 301 investigation carrying tariff-imposition authority — distinct from the Special 301 process (Section 182, which designates but cannot impose tariffs) and from the simultaneous June 2, 2026 forced-labor Section 301 (60 economies) and March 11, 2026 overcapacity Section 301. USTR proposes additional duties of 10–12.5% on Vietnamese goods if the investigation confirms actionable IP failures. The public comment period closes July 6, 2026.
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 at the Quad Foreign Ministers' Meeting in New Delhi, the United States, Japan, Australia, and India signed the Quad Critical Minerals Initiative Framework, committing to mobilise up to USD 20 billion in combined government and private-sector investment for mining, processing, refining, and recycling of critical minerals across the Indo-Pacific. The framework coordinates investment-policy tools, exploration support, market-development instruments, and supply-chain financing across all four members, with the explicit aim of diversifying critical mineral supply chains away from single-point dependencies in processing. It is the first Quad-format multilateral critical minerals commitment and represents a structural coordination layer atop existing bilateral frameworks (US-Japan, US-India, Japan-France) and national strategies.
On 20 May 2026, the Council of the EU and the European Parliament reached a provisional political agreement on two Commission regulations implementing the tariff elements of the EU-US Joint Statement of 21 August 2025. The main regulation (COM(2025)0471) eliminates remaining EU customs duties on US industrial goods and grants preferential market access for US seafood and non-sensitive agricultural products. The second regulation (COM(2025)0472) extends the suspension of EU duties on US lobster imports (including processed lobster) retroactively from 1 August 2025. Both regulations sunset on 31 December 2029 and include a Commission safeguard mechanism to suspend concessions if the US fails to meet its Joint Statement commitments.
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 13 May 2026, Entreprise Générale du Cobalt (EGC — the DRC state cobalt monopsony), Trafigura Pte Ltd, and EVelution Energy LLC signed a tripartite MOU in Madrid to establish a long-term supply framework for Congolese cobalt hydroxide to the United States. EGC will originate cobalt hydroxide from artisanal and small-scale mining; Trafigura will provide logistics and marketing services; EVelution will process the material into battery-grade cobalt sulfate and alloy-grade cobalt metal at a new first-of-kind commercial-scale refinery in Yuma County, Arizona (construction 2027, target completion 2029). The arrangement is designed to supply approximately 40% of projected US cobalt demand for aerospace, defence, and EV batteries. The MOU operationalises the December 2025 US-DRC Strategic Partnership Agreement at the commercial supply-chain level, creating a primary DRC→US cobalt flow that bypasses Chinese refiners.
On 8 May 2026 the US Department of Commerce and South Korea's Ministry of Trade, Industry and Resources (MOTIR) signed the Korea-U.S. Shipbuilding Partnership Initiative (KUSPI) MOU, establishing a standing bilateral platform covering commercial shipbuilding cooperation, workforce development, industrial modernisation, and maritime manufacturing investment. The agreement creates the Korea-U.S. Shipbuilding Partnership Center in Washington D.C. (expected operational later in 2026) as the permanent coordination mechanism for technical exchanges, shipyard productivity improvement projects, FDI into the US maritime industrial base, and joint workforce training. KUSPI operationalises the $150 bn Korean investment sub-pledge to US shipbuilding — itself a tranche of the broader $350 bn / $20 bn-annual-cap commitment under the December 2025 US-Korea Strategic Trade and Investment Deal — and structurally positions the US-ROK allied axis as the coordinated civilian shipbuilding counterweight to China's dominant global shipyard share.
A divided three-judge panel of the US Court of International Trade (CIT), in Slip Op. 26-47 (Court Nos. 26-01472 and 26-01606, decided 7 May 2026), held 2-1 that President Trump's Proclamation 11012 — which imposed a temporary 10% ad-valorem import surcharge under Section 122 of the Trade Act of 1974 — exceeded statutory authority because the proclamation did not identify a "fundamental international payments problem" as defined by the 1974 Congress (the balance-of-trade or current-account deficit relied upon by the government is not the type of balance-of-payments deficit the statute contemplates). The court issued a permanent injunction prohibiting CBP from collecting Section 122 duties from the three prevailing plaintiff- importers and ordered refunds with statutory interest for duties already paid; it declined to issue a nationwide injunction. The US Court of Appeals for the Federal Circuit (CAFC) entered an administrative stay of the CIT injunction on 12 May 2026 pending appeal, and the CIT denied the government's own motion to stay its ruling on 20 May 2026; the CAFC appeal is now pending.
On 2 May 2026, MOFCOM issued Announcement No. 21 of 2026 — the first concrete prohibition order ever issued under China's 2021 "Rules on Counteracting Unjustified Extra-territorial Application of Foreign Legislation and Other Measures" (Blocking Rules) and the Anti-Foreign Sanctions Law (AFSL). The order prohibits any Chinese organisation, individual, or foreign party operating in China from recognising, enforcing, or complying with US sanctions imposed under Executive Orders 13902 and 13846 against five Chinese independent ("teapot") refineries — Hengli Petrochemical (Dalian) Refining Co., Ltd., Shandong Shouguang Luqing Petrochemical Co., Ltd., Shandong Jincheng Petrochemical Group Co., Ltd., Hebei Xinhai Chemical Group Co., Ltd., and Shandong Shengxing Chemical Co., Ltd. — all designated by OFAC for purchasing Iranian crude. The announcement is the first operational test of the framework built up across the AFSL (2021), the AFSL Implementation Regulations (Order 803, March 2025), and State Council Order 835 on Countering Foreign Unlawful Extraterritorial Jurisdiction (April 2026), and creates a direct compliance conflict for banks, insurers, traders, and shipping companies operating in or with China that had been winding down their exposure to the listed refineries.
President Trump signed Executive Order 14404, "Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy," on 1 May 2026. The order operationalises the country-specific national emergency declared by EO 14380 (29 January 2026) — which had been preserved after the SCOTUS *Learning Resources* vacatur of the IEEPA tariff authority — by establishing a sectoral OFAC blocking regime. Section 2 authorises asset-blocking against any foreign person determined by the Secretary of Treasury (in consultation with State) to operate in Cuba's energy, defense and related materiel, metals and mining, financial services, or security sectors, or "any other sector" subsequently designated. Section 3 suspends entry under INA § 212(f) for covered aliens. Section 4 authorises secondary sanctions against foreign financial institutions that knowingly conduct or facilitate significant transactions for blocked persons, with both correspondent-account and SDN-listing remedies. The EO itself includes no annex of named designations — those are issued by OFAC under separate determinations.
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 30, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) added former Democratic Republic of the Congo President Joseph Kabange Kabila to the Specially Designated Nationals (SDN) List pursuant to Executive Order 13413, as amended by Executive Order 13671 (the DRC sanctions program), for having materially assisted, sponsored, or provided financial, material, or technological support to the March 23 Movement (M23) and its political-military coalition the Congo River Alliance (Alliance Fleuve Congo, AFC). Treasury press release SB0480 ("Treasury Sanctions Former Democratic Republic of the Congo President for Ties to Armed Conflict") frames the designation as enforcement of the Washington-brokered DRC-Rwanda framework: M23 controls a substantial share of mineral-rich eastern DRC (cobalt, coltan, tin, tungsten, gold) and AFC's renewed rebellion has fuelled a mass-displacement crisis. The notice was published in the Federal Register on May 5, 2026 (FR Doc. 2026-08672). The designation blocks all property and interests in property of Kabila subject to US jurisdiction and prohibits US-person dealings with him. It is a discrete enforcement step under the broader US-DRC Strategic Partnership Agreement (4 December 2025 — the "Washington Accords") and complements earlier 2026 designations of Rwanda Defence Force-linked actors. Treasury frames the action as signalling that political support to M23/AFC, not just direct military or commercial activity, will trigger blocking sanctions.
The Office of the United States Trade Representative released the 2026 Special 301 Report on 30 April 2026, designating Vietnam as a Priority Foreign Country (PFC) — the most severe category under Section 182 of the Trade Act of 1974 (19 U.S.C. § 2242). This is the first PFC designation since Ukraine held the status from 2013 through 2015, a gap of approximately 11 years. The PFC designation triggers a statutory 30-day window (expiring ~30 May 2026) within which USTR must decide whether to initiate a Section 301 investigation under 19 U.S.C. § 2412(b)(2)(A), which could lead to tariffs, withdrawal of trade benefits, or other Section 301 enforcement remedies against Vietnam. Separately, the EU was added to the Watch List for the first time, citing AI training-data, geographical-indications, and customs-enforcement concerns.
On 27 April 2026, US Assistant Secretary of State Caleb Orr and Bolivian Mining Minister Marco Antonio Calderón signed a Critical Minerals Memorandum of Understanding in Washington DC, establishing a non-binding cooperation framework targeting lithium, cobalt, and copper supply chains. The MoU is the first major bilateral economic instrument between the US and Bolivia since the 2008–09 expulsion of the US Ambassador, marking a strategic realignment by the post-Paz government toward Western investment partnerships. The agreement commits both governments to attract private-sector investment to Bolivia's critical-minerals endowment — including the Salar de Uyuni lithium resource (~21 Mt LCE, world's largest identified reserve) — as operational follow-through to Bolivia's February 2026 Critical Minerals Ministerial participation and the FORGE launch. It runs in parallel with Bolivia's domestic Proyecto de Ley del Litio (filed December 2025), which would open extraction-stage YLB operations to private partnership and introduce a progressive royalty structure.
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).
The US Department of Commerce published preliminary affirmative antidumping duty (AD) determinations on April 23, 2026 (Federal Register publication April 28, 2026), finding that crystalline silicon photovoltaic cells (whether or not assembled into modules) from India, Indonesia, and Laos are being sold in the US at less than fair value. Preliminary dumping margins are 123.04% for India, 35.17% for Indonesia, and 22.46% for Laos, with Commerce ordering US Customs and Border Protection to begin collecting AD cash deposits at those rates (107.77% adjusted cash-deposit rate for India; 22.06% for Laos). This runs parallel to, and stacks on top of, the CVD case on the same merchandise and countries (see responds_to), meaning combined AD+CVD cash-deposit burdens on subject imports now exceed 100% for all three origins. Final AD determinations are due July 13, 2026 (India, Indonesia) and September 9, 2026 (Laos).
President Trump issued five Presidential Determinations on 20 April 2026 under Section 303 of the Defense Production Act of 1950 (50 U.S.C. § 4533), invoking the authority granted by Executive Order 14156 (Declaring a National Energy Emergency, signed 20 January 2025). The five determinations cover: (1) domestic petroleum production, refining, and logistics; (2) large-scale energy and energy-related infrastructure development, manufacturing, and deployment; (3) natural gas transmission, processing, storage, and LNG capacity; (4) coal supply chains and baseload power generation; (5) grid infrastructure, equipment, and supply chain. Each determination authorises the relevant Cabinet Secretary (primarily Energy) to use DPA §303 powers — direct loans, loan guarantees, purchase commitments, and equity investments — to expand domestic capacity in the named category.
On 2 April 2026 President Trump issued a Presidential Proclamation under Section 232 of the Trade Expansion Act of 1962 ("Adjusting Imports of Pharmaceuticals and Pharmaceutical Ingredients into the United States") imposing a 100% ad valorem tariff on imports of patented pharmaceutical products listed in the FDA Orange Book and Purple Book, together with the active pharmaceutical ingredients (APIs) and key starting materials used to make them. The base rate takes effect at 12:01 a.m. EDT on 31 July 2026 for the 17 manufacturers identified in Annex III, and on 29 September 2026 for all other companies. The proclamation adopts findings of the Section 232 investigation initiated by the Department of Commerce on 14 April 2025 into pharmaceuticals and APIs as a national- security supply-chain risk. The instrument is structured around a multi-tier rate ladder rather than a flat tariff: concessionary 15% rates for EU/Japan/South Korea/Switzerland/Liechtenstein under reciprocal-deal tracks, 10% for the UK with a pathway to 0% under the pending UK pharmaceutical agreement, a "+20%" surcharge for companies operating under a Commerce-approved onshoring plan (until 2 April 2030), and a 0% pathway for companies that combine an approved onshoring plan with an MFN-pricing agreement with HHS (until 20 January 2029). Generics, biosimilars and their ingredients, orphan drugs, nuclear medicines, plasma-derived therapies, fertility treatments, and cell/gene therapies are carved out.
The Department of Commerce's International Trade Administration published a Federal Register notice on 10 April 2026 (91 FR 18412, doc 2026-06952) opening the inaugural Call for Proposals for the American AI Exports Program established under Executive Order 14320. Proposals are accepted from 1 April 2026 through 5:00 pm EDT on 30 June 2026 from US industry-led "pre-set" consortia offering full-stack American AI export packages — AI-optimised hardware, data pipelines, AI models and systems, security and cybersecurity measures, and sector-specific applications — for presentation by the US government to foreign public- and private-sector buyers. Designated consortia receive priority US-government advocacy, priority consideration for export-control licence engagement, interagency coordination, and federal-financing referrals (EXIM, DFC), with a 14-business-day completeness review and 60-calendar-day designation decision once a proposal is deemed complete.
Brazil's Comitê-Executivo de Gestão da Câmara de Comércio Exterior (Gecex/Camex) approved Resolução Gecex Nº 876 on 13 April 2026 (DOU 14/04/2026), applying a definitive five-year antidumping duty on imports of polyethylene (PE) resins — NCM 3901.10.30, 3901.20.29, and 3901.40.00 — originating from the United States and Canada. The DECOM investigation, initiated on 14 November 2024 following a Braskem S.A. petition, found positive dumping margins and material injury to the domestic PE-resin industry; provisional duties were imposed under Resolução Gecex Nº 777 (28 August 2025) for six months. Gecex modulated the definitive rates to match provisional-period levels as a public-interest adjustment to limit additional cost pass-through to downstream packaging, agricultural-film, and container manufacturers.
On March 20, 2026, OFAC issued Iran-related General License U (GL U), temporarily authorizing the sale, delivery, offloading and — notably, for the first time in decades — importation into the United States of Iranian-origin crude oil and petroleum products, but only for cargo already loaded onto vessels as of 12:01 a.m. EDT that day. The window ran through April 19, 2026, after which the authorization lapsed. The license excluded any transaction touching Cuba, North Korea, or Russian-government-controlled areas of Ukraine, and did not waive any other, non-Iran sanctions program. OFAC formally published GL U (and the separate, entity-specific GL V wind-down license for Hengli Petrochemical) in the Federal Register on June 10, 2026 — a retrospective publication of licenses already issued and, by then, already expired.