Industrial Policy & Trade Monitor· 2671 actions· ✨ 89 recent

On 11 October 2024, the Secretary of the Treasury — acting in consultation with the Secretary of State and pursuant to section 1(a)(i) of Executive Order 13902 — determined that the petroleum and petrochemical sectors of the Iranian economy are sectors of strategic concern, exposing non-US persons that operate in or knowingly facilitate significant transactions with those sectors to secondary sanctions and SDN-listing risk. The determination was issued in response to Iran's 1 October 2024 ballistic- missile attack on Israeli targets and was formally published in the Federal Register on 19 November 2024 (FR Doc 2024-26800). Concurrent with the determination, OFAC designated an international network — including Sepehr Energy Jahan Nama Pars — that had shipped millions of barrels of Iranian crude on behalf of Iran's Armed Forces General Staff to the People's Republic of China.

FinCEN issued a final order, published in the Federal Register on 11 October 2024 (signed 26 September 2024), prohibiting US covered financial institutions from engaging in transmittals of funds to or from PM2BTC, a virtual-currency exchange operating outside the United States and identified as a primary money-laundering concern in connection with Russian illicit finance. The order is the first use of FinCEN's special- measure authority under Section 9714(a) of the Combating Russian Money Laundering Act, as amended by the FY 2022 NDAA (codified at 31 U.S.C. 5323). The action was coordinated with same-day OFAC SDN designations of related entities (Cryptex) and individuals (Sergey Sergeevich Ivanov of Taleon Holdings).

The US Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register reporting instructions implementing Section 104(a) of the Rebuilding Economic Prosperity and Opportunity (REPO) for Ukrainians Act (P.L. 118-50, Division F, enacted April 24, 2024). All US financial institutions at which Russian sovereign assets are located — or that know or should know of such assets, including in correspondent or payable-through accounts — must report those holdings to OFAC using Form TD-F 93.09. Initial reports were due by August 2, 2024, with rolling reports required within 10 days of detecting newly identified Russian sovereign assets. The notice is the predicate step for any future US seizure or transfer of frozen Russian central bank, National Wealth Fund, or Russian Ministry of Finance assets to benefit Ukraine.

President Lukashenko signed Decree No. 278 on 10 July 2024, extending the prohibitive import customs duty regime established under Decree No. 16 (12 January 2024) through 30 June 2025, preventing its lapse at year-end 2024. The decree also expands the commodity list subject to elevated import duty rates. The measure explicitly frames the duties as retaliatory, targeting goods originating from states designated as "unfriendly" to Belarus — principally EU member states, the US, UK, Canada, Japan, Australia, New Zealand, Switzerland, Norway, Iceland, and other sanctioning jurisdictions. Co-ordinated with Russia's EAEU parallel-import framework (Resolution No. 506), the regime affects the cost arithmetic for sanctioned-goods routing through EAEU customs-union channels and signals continued institutionalisation of Belarus's counter-sanctions architecture.

OFAC final rule (FR Doc 2024-11618, 89 FR 46518) amending the Cuban Assets Control Regulations at 31 CFR Part 515 to further implement the May 2022 Biden administration policy of expanded support for the Cuban people. The rule reinstates the "U-turn" general license (authorizing US banks to process funds transfers that originate and terminate outside the US, neither originator nor beneficiary a US person); replaces "self-employed individual" with the broader "independent private sector entrepreneur" (covering Cuban private businesses up to 100 employees, including private cooperatives); authorizes Cuban nationals in the private sector and located in Cuba to open and operate accounts at US financial institutions (including via online/mobile banking); and expands authorizations for internet-based services to support Cuban civil society and private-sector entrepreneurs. Effective 29 May 2024.

Presidential Decree No. 442 of 23 May 2024 establishes a special judicial-administrative procedure by which the Russian Federation or the Central Bank of the Russian Federation can claim, before a Russian court, that an "unjustified deprivation" of Russian sovereign property has been effected by a state body or judicial authority of the United States — and, on a court finding to that effect, receive equivalent-value US-affiliated property located in Russia (real assets, securities issued by Russian companies, cash held in Russian bank accounts, and other property rights) by way of compensation. The mechanism is an explicit reciprocal counter-instrument to the US REPO for Ukrainians Act (Title II of H.R.815, signed 24 April 2024) authorising US executive confiscation of immobilised Russian sovereign assets in US jurisdiction. The decree is structurally extensible: by separate presidential decision, the same procedure may be applied to any other state Russia designates as "unfriendly". Implementing procedural acts and amendments to Russian legislation were required to be adopted by 23 September 2024.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) issued a final rule amending 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) to incorporate, with amendments, General License (GL) D-2 — originally issued on OFAC's website on September 23, 2022 — which authorizes the export, reexport, and provision of certain services, software, and hardware incident to communications over the internet to persons in Iran. The codification preserves the GL D-2 expansion (cloud-based services; third-country importation of hardware/software previously exported to Iran; ex-Iran installation, repair and replacement services; case-by-case licensing for internet-freedom activities) and updates the § 560.540 List of Services, Software, and Hardware Incident to Communications. Effective June 17, 2024, the List is amended to exclude laptops, tablets, and personal computing devices with an Adjusted Peak Performance (APP) exceeding 1 Weighted TeraFLOP (WT) — narrowing the consumer-electronics authorization to lower-performance devices and aligning the carve-out with broader BIS-style compute thresholds. The rule does not relax primary ITSR prohibitions; it codifies a humanitarian / internet-freedom exception while inserting a narrow high-performance-compute carve-out.

President Biden signed into law on 13 May 2024 the Prohibiting Russian Uranium Imports Act (Division H of the National Security Supplemental Appropriations Act, Public Law 118-50). The law bans imports to the United States of unirradiated low-enriched uranium (LEU) produced in Russia or by Russian state entities, effective immediately, with a waiver mechanism allowing the Department of Energy to grant case-by-case exceptions through 2027 where no alternative supply is available. The law also authorised up to $2.72B to support US uranium enrichment capacity via CENTRUS and allied enrichment partnerships.

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register "Directive 1 under Executive Order 14014, 'Prohibitions Related to Financial Services to or for the Benefit of Myanma Oil and Gas Enterprise.'" The Directive — originally issued on OFAC's website on 2023-10-31 with a 2023-12-15 effective date — determines that MOGE is a political subdivision, agency, or instrumentality of the Government of Burma and prohibits U.S. persons from providing, exporting, or reexporting, directly or indirectly, financial services to or for the benefit of MOGE. The Federal Register publication codifies notice of the Directive in the formal record of agency action; the underlying prohibition has been operative since December 2023.

OFAC issued two determinations under Executive Orders 14068 and 14071 banning the import into the United States of Russian-origin aluminum, copper, and nickel produced on or after April 13, 2024, and separately prohibiting the provision of warranting/deliverable services for these metals on global exchanges (LME, CME) and their use to settle over-the-counter derivative contracts. Metal produced before the effective date is grandfathered. The action was coordinated with the United Kingdom, which imposed parallel exchange-listing prohibitions the same day, following G7 statements on reducing Russia's metals revenue.

OFAC amended § 510.512 of the North Korea Sanctions Regulations (31 CFR Part 510) to broaden the scope of authorized humanitarian activities for NGOs operating in North Korea, including permitting transactions with certain Government of North Korea entities where necessary to deliver authorized services. Three new general licenses were added: one for exports and re-exports of items licensed by the Commerce Department; one for agricultural commodities, medicine, and medical devices; and one for journalistic activities in North Korea. NGOs relying on the authorization must notify the State Department at least 30 days before commencing activity.