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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.
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.
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).
On 10 July 2026 OFAC issued Iran General License Y, authorizing the wind down of transactions involving Smart Global Limited (a Saint Kitts and Nevis holding company designated the same day alongside 5 other entities and 8 individuals), with payments to blocked parties to go into blocked accounts; it expired 9 August 2026. On 14 July 2026 OFAC issued General License Z under E.O. 13902, authorizing wind-down activity for blocked persons and vessels listed in an 11-entry annex (financial wind-down, safe port docking and departure, crew safety, emergency repairs, offloading of pre-14 July cargo); it expired 12 September 2026. Both licenses were formally published in the Federal Register on 23 September 2026 (91 FR 60304).
On May 1, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated China-based independent ("teapot") refinery Hengli Petrochemical (Dalian) Refinery Co., Ltd. — described as China's second-largest teapot — together with approximately 40 shipping firms and vessels operating as part of Iran's shadow fleet. OFAC sanctioned 19 shadow-fleet vessels (crude, LPG, and petrochemical tankers) as blocked property of designated owners or managers. The action was taken under Executive Order 13902 (Iran petroleum and petrochemical sectors) in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. Treasury press release SB0472. Concurrent with the designations, OFAC issued Iran-related General License W authorising the wind-down of transactions involving the persons newly blocked on May 1, 2026, and published a structurally novel Iran-related Alert, "Sanctions Risks of Iranian Demands for Strait of Hormuz Passage." The Alert states that payments to the Government of Iran or the IRGC — directly or indirectly — for safe passage through the Strait of Hormuz are not authorised for US persons (including US financial institutions) or US-owned/-controlled foreign entities. OFAC also issued new FAQ 1250 to accompany the Alert and GL W. The wave is one of the largest single-day Iran enforcement actions of the Trump 2.0 administration. Treasury characterises it as part of a campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The Strait of Hormuz Alert is the operational US response to Iranian regulatory threats against the ~20% of global oil and ~25% of global LNG transiting Hormuz, putting tanker owners, P&I clubs, flag states, and oil-buyer compliance teams on direct notice.
On April 24, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) added 19 entities and 19 vessels to the Specially Designated Nationals (SDN) List under Executive Order 13902 (Iran petroleum and petrochemical sectors), in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. The action is the first OFAC designation of a Chinese independent ("teapot") refinery — Hengli Petrochemical (Dalian) Refinery Co., Ltd., described as one of Iran's largest single customers for crude oil and petroleum products, having purchased billions of US dollars' worth since at least 2023 from cargoes brokered by Sepehr Energy Jahan Nama Pars Company (the oil sales arm of Iran's Armed Forces General Staff, controlled by the Ministry of Defense / MODAFL). Co-designations span shipping firms and vessels registered in China, Hong Kong, Panama, Marshall Islands, Liberia, and Vietnam. Concurrent with the designations, OFAC issued Iran-related General License V authorising a 30-day wind-down (through May 24, 2026) of transactions involving Hengli Petrochemical (Dalian) Refinery Co., Ltd. and certain majority-owned entities. Treasury press release SB0472 ("Economic Fury Targets Global Network Fueling Iran's Oil Trade and Shadow Fleet") frames the action as part of the maximum-pressure campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The April 24 designations directly triggered the first-ever operational use of China's Blocking Rules (MOFCOM Announcement No. 21 of May 2, 2026) and preceded a second OFAC Iran wave on May 1, 2026 (General License W + Strait of Hormuz Sanctions Risk Alert).
President Trump signed Executive Order 14382, "Addressing Threats to the United States by the Government of Iran," on 6 February 2026 (effective 12:01 a.m. EST on 7 February 2026; published in the Federal Register on 11 February 2026 as FR doc 2026-02813, 91 FR 6493-6496). Invoking IEEPA, the National Emergencies Act, section 604 of the Trade Act of 1974 and 3 U.S.C. § 301, the order declared a country-specific national emergency with respect to Iran and established a secondary-tariff-authority framework: an additional ad valorem duty (the EO offers "for example, 25 percent" as illustration but sets no binding rate) is authorised on imports of articles produced by any foreign country determined to directly or indirectly purchase, import, or otherwise acquire any goods or services from Iran. Determinations are made by the Secretary of Commerce, with rate recommendations from the Secretary of State in consultation with Treasury, DHS and USTR; the President retains final authority. EO 14382 was structurally modelled on EO 14245 (Venezuelan oil importing countries, 24 March 2025) and EO 14380 (Cuba, 29 January 2026), and was on the list of nine IEEPA-based tariff EOs whose tariff component was vacated by the SCOTUS 6-3 ruling in *Learning Resources, Inc. v. Trump* (20 February 2026). The companion EO 14389 of 20 February 2026 ("Ending Certain Tariff Actions") extinguished the tariff authority for entries on or after 12:00 a.m. ET on 24 February 2026; the underlying Iran national- emergency declaration was preserved. No third-country determination or specific rate was operationalised under EO 14382 prior to vacatur.
President Trump signed Executive Order 14380, "Addressing Threats to the United States by the Government of Cuba," on 29 January 2026 (effective 12:01 a.m. EST on 30 January 2026; published in the Federal Register on 3 February 2026 as FR doc 2026-02250, 91 FR 5085-5089). Invoking IEEPA and the National Emergencies Act, the order declared a country-specific national emergency with respect to Cuba, citing Havana's intelligence and defense alignment with Russia, the PRC, Iran, Hamas and Hezbollah — including the Russian signals-intelligence facility hosted on the island. The operative measure was a secondary-tariff-authority framework: the EO authorises additional ad valorem duties on goods imported from any country determined to be selling or otherwise providing oil to the Government of Cuba, whether directly or indirectly. No specific rate was set in the EO itself — rate-setting was delegated to the Secretary of Commerce (in consultation with State, Treasury, DHS and USTR). The EO was structurally analogous to EO 14245 (Venezuelan oil importing countries, 24 March 2025) and was on the list of nine IEEPA-based tariff EOs whose tariff component was vacated by the SCOTUS 6-3 ruling in *Learning Resources, Inc. v. Trump* (20 February 2026); the underlying Cuba national-emergency declaration was preserved by the 20 February 2026 "Ending Certain Tariff Actions" EO, but the tariff authority was extinguished before any third-country determination or rate was operationalised.
On January 23, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated eight vessel-owning/management firms — based in the UAE, India, Oman, the Seychelles, and the Marshall Islands — and identified nine of their tankers as blocked property, for transporting hundreds of millions of dollars' worth of Iranian crude oil, LPG, naphtha and high-sulfur fuel oil to buyers across East Asia, South Asia and East Africa. The action was taken under Executive Order 13902 (Iran petroleum/petrochemical sector) as part of the maximum-pressure campaign under National Security Presidential Memorandum 2, and OFAC concurrently issued General License T authorizing limited safety, environmental and cargo-offloading transactions involving the newly blocked vessels.
On 16 January 2026, the US Treasury's Office of Foreign Assets Control designated 21 individuals and entities and identified one vessel for transferring oil products, procuring weapons and dual-use equipment, and providing financial services to Iran-backed Ansarallah (the Houthis). Designated parties — oil-trading and exchange companies, a shipping/logistics facilitator, and front-company operatives — are based in Yemen, Oman, and the UAE, and are accused of running an oil-sales and financial- facilitation network that Treasury says generates the Houthis over $2 billion in annual illicit revenue. The action was taken pursuant to Executive Order 13224 (as amended) and builds on a multi-year cadence of prior OFAC designations against Houthi leaders, smugglers, financiers, and weapons-procurement suppliers.
On December 18, 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated 29 shadow-fleet vessels and 17 vessel-management/shipping firms — plus Egyptian businessman Hatem Elsaid Farid Ibrahim Sakr and two of his UAE-registered companies (Red Sea Ship Management LLC and High Seas Petroleum LLC) — under Executive Order 13902 for operating in Iran's petroleum sector. The vessels, flagged across Palau, Panama, Cook Islands, Barbados, Jamaica and unknown registries, are said to have transported "hundreds of millions of dollars'" worth of Iranian crude oil, fuel oil, bitumen, naphtha and condensate to buyers in Asia. Treasury frames the action as part of a campaign that has sanctioned more than 180 vessels since President Trump resumed office in January 2025, implementing NSPM-2 maximum-pressure policy.
On 11 December 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated six shipping companies — registered in the Marshall Islands (4), British Virgin Islands (1), and the United Kingdom (1) — and their six crude-oil tankers as blocked property under Executive Order 13850 for operating in Venezuela's oil sector. The vessels (WHITE CRANE, KIARA M, MONIQUE, LATTAFA, H. CONSTANCE, and TAMIA) had loaded Venezuelan crude in September/October 2025 and allegedly used AIS spoofing and other deceptive shipping practices to evade detection. The same action separately designated four individuals — including two nephews of Cilia Flores (Nicolas Maduro's wife) under the counter-narcotics authority EO 14059, a former PDVSA official under EO 13692, and a Panamanian facilitator under EO 13850 — but the shipping-company/tanker designations are the action's primary trade-control component.
At the APEC Busan summit on 30 October 2025, Presidents Trump and Xi reached the "Economic and Trade Arrangement Between the United States and the People's Republic of China," subsequently implemented on the US side by the executive order "Modifying Reciprocal Tariff Rates Consistent with the Economic and Trade Arrangement" (issued 4 November 2025; effective 12:01 am EST on 10 November 2025; published in the Federal Register on 7 November 2025 as 90 FR 50729 / 2025-19826) and on the Chinese side by a series of MOFCOM and State Council Tariff Commission announcements (notably MOFCOM 2025 No. 90 of 8–9 November 2025). The arrangement is structurally parallel to the already-filed US-Japan, US-Korea and US-Taiwan framework deals but uniquely material because it freezes the highest-stakes bilateral tariff and export-control confrontation of the post-2024 reset. Core US commitments: (i) reciprocal-tariff "additional ad valorem rate of duty" on PRC-origin goods reduced from a prior 20% IEEPA-fentanyl + 10% IEEPA-reciprocal stack to a 10% rate (i.e., the prior 24% / 34% scheduled escalation is suspended), extended through 10 November 2026; (ii) US BIS suspends the so-called "affiliates rule" expanding entity-list controls to majority-owned subsidiaries of listed Chinese firms; (iii) USTR pauses Section 301 maritime / shipbuilding / logistics countermeasures against Chinese vessels for one year. Core PRC commitments: (i) MOFCOM suspends for one year (until 10 November 2026) the 9 October 2025 extraterritorial rare-earth export-control package — including controls on REE processing equipment, lithium-battery manufacturing equipment, and superhard materials; (ii) PRC suspends retaliatory tariffs on a broad swath of US agricultural products through 31 December 2026; (iii) commitment to purchase ≥25 million metric tonnes of US soybeans annually in 2026-2028 and to resume sorghum and log imports; (iv) suspension of MOFCOM antitrust and "unreliable-entity" probes against named US semiconductor and chip-equipment companies; (v) cooperation on fentanyl precursor enforcement. The arrangement does not repeal underlying authorities (IEEPA tariffs, MOFCOM export-control list, Entity List) — it is a calibrated mutual freeze with a one-year sunset and quarterly review checkpoints.
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 11 September 2025, the US Treasury's Office of Foreign Assets Control designated 32 individuals and entities and identified four vessels in what Treasury described as its broadest sanctions action to date against Iran-aligned Ansarallah (Houthi) support networks. The designated network — companies, owners, and operatives located in Yemen, China, the UAE, and the Marshall Islands — is accused of running oil and commodity smuggling through Houthi-controlled Yemeni ports, laundering the proceeds, and using them to finance a global weapons procurement supply chain of front companies and shipping facilitators. The action was taken pursuant to Executive Order 13224 (as amended) and builds on nine prior 2024-2025 OFAC actions against Houthi leaders, smugglers, financiers, and suppliers.
On 3 September 2025, OFAC announced a civil penalty settlement with Fracht FWO Inc. — a Houston, Texas-based freight forwarder and US subsidiary of Switzerland-headquartered Fracht AG — under which the company agreed to pay USD 1,610,775 to settle its potential civil liability for apparent violations of multiple OFAC sanctions programs. The violations arose from Fracht FWO's brokering of cargo shipments involving EMTRASUR, a wholly owned subsidiary of OFAC-designated Venezuelan state airline CONVIASA, on a Mexico-to-Argentina route on which Iranian crew members were subsequently discovered. Fracht self-initiated a voluntary disclosure to OFAC after learning of the Iranian crew involvement, triggering mitigating credit, and undertook extensive remedial compliance measures. The settlement resolves apparent violations of the Venezuela Sanctions Regulations (VSR), Weapons of Mass Destruction Proliferators Sanctions Regulations (WMDPSR), Global Terrorism Sanctions Regulations (GTSR), and Iranian Transactions and Sanctions Regulations (ITSR).
On 2 September 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated Waleed Khaled Hameed al-Samarra'i, a dual Iraqi/St Kitts-and-Nevis citizen, along with his UAE-based shipping manager Babylon and five Marshall Islands-registered shell companies (Tryfo Navigation, Keely Shiptrade, Odiar Management, Panarea Marine, Topsail Shipholding) that hold registered ownership of nine Liberia-flagged tankers (ADENA, LILIANA, CAMILLA, DELFINA, BIANCA, ROBERTA, ALEXANDRA, BELLAGIO, PAOLA). The network blends Iranian crude with Iraqi oil via ship-to-ship transfers in the Arabian Gulf and at Iraqi ports, then markets the blend as solely Iraqi-origin to evade US sanctions, generating hundreds of millions of dollars for the Iranian regime and al-Samarra'i. The action was taken pursuant to Executive Order 13902 and blocks all US property and interests of the designated individual, entities and vessels.
On 30 July 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated more than 50 individuals and entities and identified more than 50 vessels belonging to the shipping empire of Mohammad Hossein Shamkhani, son of Ali Shamkhani, a top political adviser to Iran's Supreme Leader. Treasury described the action — over 115 sanctions in total — as its largest Iran-related action since 2018. The network launders billions of dollars from sales of Iranian and Russian crude oil and petroleum products (mostly to buyers in China) through vessels and front companies registered across the UAE, Hong Kong, India, Cyprus, Panama, Romania, China, Liberia, the Marshall Islands and Seychelles. Concurrently, the State Department designated 20 entities and identified 10 vessels under E.O. 13846 and E.O. 13902 for trading and transporting Iranian petroleum and petrochemical products.
On 3 July 2025, the US Treasury's Office of Foreign Assets Control designated a network of UAE- and UK-based companies controlled by Iraqi-British businessman Salim Ahmed Said that has smuggled Iranian oil disguised as Iraqi crude since at least 2020, plus five additional shadow-fleet vessel owners based in Seychelles, the Marshall Islands, and the British Virgin Islands. The action, taken pursuant to E.O. 13902 (Iran petroleum sector) and E.O. 13224 (counterterrorism), also identifies several tankers as blocked property and marks the eighth round of sanctions under National Security Presidential Memorandum 2's Iran maximum-pressure campaign. Concurrently, the State Department designated six additional entities and four vessels under E.O. 13846.
On 20 June 2025, the US Treasury's Office of Foreign Assets Control designated four individuals, twelve entities, and two vessels in what Treasury called its single largest action to date against Iran-backed Ansarallah (the Houthis), pursuant to Executive Order 13224 as amended. The designated network — Sana'a- and Hudaydah-based oil-trading front companies (including Black Diamond Petroleum Derivatives, Star Plus Yemen, Tamco Establishment, Royal Plus Shipping, and Abbot Trading) and their Houthi operator-owners — facilitates black-market oil and oil-derivative sales that fund Houthi militant operations, while shipping firms Best Way Tanker Corp, Ocean Voyage LLC, and Atlantis M. Shipping Co were designated for discharging over 120,000 combined metric tons of gasoline and LPG at the Houthi-controlled Ras Isa port via the vessels Valente and Atlantis MZ after the April 2025 expiration of Counter Terrorism General License 25A. The action builds on OFAC's June 2024–April 2025 cadence of designations against Houthi leaders, weapons-procurement operatives, and suppliers.
On 20 June 2025, the US Treasury's Office of Foreign Assets Control designated one individual, eight entities, and one vessel pursuant to Executive Order 13382 (WMD proliferators) for procuring and transshipping sensitive machinery to Iran's Rayan Roshd Afzar Company (RRA), a producer of UAV components and aerospace software for the IRGC. The vessel SHUN KAI XING, owned by Hong Kong-based Unico Shipping Co Ltd and chartered by Singapore-based V-Shipping Pte Ltd, was carrying the machinery for RRA and an affiliated firm when its cargo was inspected; the designated network — including China-based Shenzhen Xinxin Shipping, Dongguan Zanyin Machinery and Equipment, Athena Shipping, shipmaster Zhang Yanbing, and Turkiye-based Edisa Dis Ticaret Limited Sirketi — then falsified bills of lading to obscure the Iran-bound, RRA-consigned cargo after the inspection.
On 13 May 2025, the US Treasury's Office of Foreign Assets Control designated nearly two dozen firms and individuals — including Hong Kong-based intermediary Star Energy International Limited — for operating in Iran's illicit international oil trade on behalf of Sepehr Energy Jahan Nama Pars Company (Sepehr Energy), the Tehran-based oil-sales arm of Iran's Armed Forces General Staff (AFGS). The designated network spans commercial intermediaries and shipping counterparties across China, Hong Kong and Singapore, the last a hub for ship-to-ship transfers of Iranian-origin crude. Designations were made under counter-terrorism (SDGT) and Iran Financial Sanctions Regulations (IFSR) authorities as part of the administration's maximum-pressure campaign to cut off military and IRGC-linked revenue from Iran's oil exports.
On 8 May 2025, the US Treasury's Office of Foreign Assets Control designated China-based "teapot" refinery Hebei Xinhai Chemical Group Co., Ltd. and its Singapore-based broker subsidiary Xing AO Energy PTE. LTD., three firms tied to a Dongying Port (Shandong) terminal that has received Iranian crude from shadow-fleet tankers, and six Hong Kong-, UK-, and Marshall Islands-owned shadow-fleet vessels (STAR TWINKLE 6, LAMD, SKADI, BIG MAG, IMPALAS, THANE) plus their owning shipping companies and two vessel captains. It is OFAC's third action against an Iranian-oil teapot refinery and its first targeting Shandong port terminal operators, taken under E.O. 13902 (Iran petroleum/ petrochemical sector) and E.O. 13846 (NIOC support) as part of the administration's NSPM-2 maximum-pressure campaign.
On 30 April 2025 the US Department of State designated seven entities and identified two vessels as blocked property for facilitating trade in Iranian petroleum and petrochemical products, under Executive Order 13846 and in furtherance of National Security Presidential Memorandum 2 (NSPM-2, "Restoring Maximum Pressure on the Government of Iran"). The action named four UAE-based sellers and one purchaser of Iranian petrochemicals — including Solvent Organics (over $300 million in exports of Iranian-origin petrochemicals to third countries) and Alseerah Trading (over $150 million) — plus a Turkiye-based petrochemical trader, an Iran-based cargo inspection company, and a marine management company involved in transporting millions of barrels of Iranian crude. Secretary of State Marco Rubio stated the goal was to drive Iran's illicit oil and petrochemical exports, including to China, to zero.
USTR concluded its Section 301 investigation (initiated 17 April 2024) into China's targeting of the maritime, logistics, and shipbuilding sectors for dominance and on 17 April 2025 issued a Notice of Action imposing tiered port-entry service fees on Chinese-owned, -operated, and Chinese-built vessels arriving at U.S. ports starting 14 October 2025 (USD 50/net ton escalating to USD 80/NT in Apr 2026, USD 110/NT in Apr 2027, and USD 140/NT in Apr 2028; capped at 5 charges per vessel per year). The action also proposed a 100% tariff on China-built or China-component ship-to-shore cranes and additional 20-100% tariffs on China-origin shipping containers, truck chassis, and chassis parts. The entire action was subsequently suspended for one year (10 Nov 2025 through 9 Nov 2026) by USTR Modification Notice (FR 2025-19873) at presidential direction following the 1 Nov 2025 Trump-Xi trade deal.
On 4 February 2025, President Donald J. Trump signed National Security Presidential Memorandum/NSPM-2, "Imposing Maximum Pressure on the Government of the Islamic Republic of Iran, Denying Iran All Paths to a Nuclear Weapon, and Countering Iran's Malign Influence." The memorandum reimposes the first- term "maximum pressure" framework, directing the Secretaries of State and Treasury and the Attorney General to (i) drive Iran's exports of crude oil and petroleum products — including to the People's Republic of China — to zero; (ii) review and modify or rescind sanctions waivers and general licences (notably the Chabahar port waiver benefiting India); (iii) sanction shadow-fleet vessels, intermediaries, refineries (including PRC "teapot" refiners) and oil traders facilitating Iranian energy exports; and (iv) lead a diplomatic isolation campaign including a snapback of UN Security Council sanctions under JCPOA Resolution 2231 paragraph 11. Since promulgation, OFAC has designated 1,000+ Iran-related persons, vessels and aircraft and four PRC independent ("teapot") refiners alleged to have processed sanctioned Iranian crude. The DOJ is also directed to pursue impoundment of Iranian oil cargoes and seizure of Iranian assets to satisfy US-court terrorism-victim judgments.
On January 10, 2025, the US Treasury's Office of Foreign Assets Control (OFAC), acting jointly with the Department of State, designated PJSC Gazprom Neft and PJSC Surgutneftegas as Specially Designated Nationals (SDNs) under Executive Orders 13662 and 14024, alongside more than 180 oil-carrying vessels (the bulk of Russia's "shadow fleet"), dozens of opaque oil traders, two major Russia-based oilfield service providers, marine insurance companies, and senior Russian energy-sector officials. The package included a new EO 14024 sectoral determination authorizing future designations against any person operating in the Russian energy sector, plus a new EO 14071 determination prohibiting the provision of US petroleum services (extraction, drilling, production support) to persons located in the Russian Federation, effective 12:01 a.m. EST on February 27, 2025. OFAC simultaneously issued General Licenses 117 (wind-down of transactions with the newly blocked entities) and 118 (debt/equity/derivatives wind-down), both expiring February 27, 2025. The action was the largest single Russia energy-sector designation since the 2022 invasion regime began and was coordinated with parallel UK OFSI shadow-fleet designations issued the same week. The action was finalized in the closing days of the Biden administration as a deliberate tightening of the oil-revenue and shadow-fleet vectors before the January 20 transition. Subsequent enforcement and any rollback decisions fell to the incoming Trump administration.
The US Bureau of Industry and Security (BIS) final rule (89 FR 87261; FR Doc 2024-25411) added 40 entities under 42 entries plus four addresses to the Entity List under the destinations China (11), India (5), Malaysia (2), Russia (13), Singapore (1), and Turkey (14), and modified 52 existing entries across China, Estonia, Finland, India, Turkey, the UAE and the UK. The dominant rationale is Russia-diversion enforcement: Chinese, Turkish, Indian, Malaysian and Singaporean entities listed for transshipping controlled US-origin items to Russian defense end users; the 13 Russia entries cover chemical and biological warfare R&D and defense procurement networks. License requirement is "all items subject to the EAR" with a policy/presumption of denial; four China addresses get the narrower "CCL + EAR99 supp. 7" scope. Effective on publication 2024-11-01.
The US Bureau of Industry and Security (BIS) final rule (89 FR 55033; FR Doc 2024-14635) added six entries to the Entity List under the destinations of the People's Republic of China (2), South Africa (1), the United Arab Emirates (2), and the United Kingdom (1). The two PRC-based entries (Global Training Solutions Limited; Smartech Future Limited) were added for ties to an existing Entity List party and for training elements of the PRC military. The two UAE-based entries (Mega Fast Cargo LLC; Mega Technique General Trading) were added for repeated dilatory or evasive conduct during BIS end-use checks, including the provision of false, misleading, or incomplete information. The South Africa and United Kingdom entries were added for shipping or attempting to ship US export-controlled items to Russia in violation of EAR controls. License requirement is "all items subject to the EAR" with policy of presumption of denial. The rule is effective on publication, 2024-07-03.
The US Bureau of Industry and Security (BIS) final rule (89 FR 41706; FR Doc 2024-10485) added 37 entities under 37 entries to the Entity List, all listed under the destination of the People's Republic of China. BIS designated these parties for one or more of three rationales: (i) shipping US-controlled items to Russia in violation of EAR controls, (ii) attempting to acquire US-origin items to support China's military modernisation or quantum-technology capabilities, and (iii) ties to the PRC high-altitude balloon that overflew the United States in late January–early February 2023. The designations span PRC technology companies (predominantly quantum-computing firms), manufacturing companies, and research institutes. License requirement is "all items subject to the EAR" with a policy of presumption of denial and no license exceptions available. The rule is effective 2024-05-09, with publication in the Federal Register on 2024-05-14.
The Bureau of Industry and Security (BIS) removed 35 persons from the Unverified List (UVL) effective 22 August 2023, spanning seven destinations: 27 entities in China, plus one each in Indonesia, Singapore, Turkey, and UAE; two in Pakistan; and two Russian entities removed as a conforming change after being escalated to the more restrictive Entity List. The 33 cooperative removals follow successful completion of end-use checks verifying each party's bona fides under §744.15(c)(2) of the EAR. Removal restores eligibility for EAR license exceptions and eliminates the UVL Statement requirement for US exporters shipping EAR-subject items to these parties.
The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 32 persons across 13 countries to the Unverified List (UVL) on the basis that BIS was unable to verify their bona fides through end-use checks. The largest concentration is in China (14 entities), followed by the UAE (5) and Turkey (4), with single entries in Bulgaria, Canada, Germany, Indonesia, Israel, Malaysia, and Singapore. UVL placement suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement and file Electronic Export Information in the Automated Export System before shipping any item subject to the EAR. Published 24 March 2023 (88 FR 17706, FR Doc 2023-06171); effective 24 March 2023.
OFAC issued a determination under Executive Order 14071 (Russian Harmful Foreign Activities Sanctions) effective December 5, 2022, establishing a $60/barrel price cap on Russian seaborne crude oil. The measure prohibits US persons from providing six categories of covered services — trading/commodities brokering, financing, shipping, insurance (including reinsurance and P&I), flagging, and customs brokering — for the maritime transport of Russian crude oil unless the oil is purchased at or below $60/bbl. The determination was coordinated with the EU, G7 nations, and Australia as a unified coalition instrument designed to reduce Russian oil revenues while keeping global energy markets supplied. Three general licenses (GL 55, 56, 57) carved out limited exemptions for Japan's Sakhalin-2 imports, certain EU landlocked states, and vessel emergencies.
The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) on 8 February 2022 to add 33 persons — all based in China — to the Unverified List (UVL) under EAR §744.15(c), on the basis that BIS could not satisfactorily complete end-use checks for these entities for reasons outside US Government control. Placement on the UVL bars exporters from using any EAR license exception when shipping controlled items to listed parties and requires exporters to obtain a certified UVL Statement from the entity or secure a BIS export licence. Sectors represented include semiconductor manufacturing equipment, optoelectronics, UAVs, specialty chemicals, and biotechnology.
The Bureau of Industry and Security (BIS) removed three persons from the Unverified List (UVL) effective January 11, 2021 after completing successful end-use checks that verified their bona fides under §744.15(c)(2) of the Export Administration Regulations (EAR). The three removed parties are DMA Logistics GmbH (Germany), Halm Elektronik GmbH (Germany), and Integrated Production and Test Engineering / IPTE (Mexico). Removal restores eligibility for EAR license exceptions and eliminates the requirement for US exporters to obtain a signed UVL Statement before shipping items subject to the EAR to these parties.