Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

The U.S. Treasury's Office of Foreign Assets Control (OFAC) entered into a $3,103,360 settlement with Exodus Movement, Inc., a U.S.-incorporated non-custodial / self-custody crypto wallet software company, to resolve 254 apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 C.F.R. Part 560) committed between October 17, 2017 and January 4, 2019. Exodus customer-support staff provided technical and account-related support — and in 12 of the 254 instances recommended the use of virtual private networks (VPNs) to circumvent partner-exchange geoblocking controls — to users who self-identified as located in Iran, in violation of the ITSR's prohibition on the export of services to Iran (§ 560.204) and, for the 12 egregious cases, the facilitation prohibition (§ 560.203). OFAC deemed the 12 VPN-coaching cases "egregious" because Exodus personnel were generally aware of U.S. sanctions and the company's own terms of use prohibited Iran usage, yet support staff actively helped Iranian users evade controls. Exodus separately committed to invest $630,000 in additional sanctions compliance controls. The settlement is structurally novel as the first OFAC enforcement action against a Web3-infrastructure / non-custodial wallet-software vendor and establishes that OFAC will assert jurisdiction over self-custody software providers based on customer-support facilitation conduct, not just custodial flow control.

On 11 December 2025 the US Department of State announced the inaugural Pax Silica Summit, held in Washington D.C. on 12 December 2025, at which the United States, Australia, Japan, the Republic of Korea, the United Kingdom, Singapore and Israel signed the non-binding Pax Silica Declaration. The declaration commits signatories to coordinate "trusted" supply chains across the full technology stack — software, frontier foundation models, network infrastructure, compute and semiconductors, advanced manufacturing, transportation logistics, minerals refining and processing, and energy — explicitly to reduce "coercive dependencies." The coalition has since expanded to add the United Arab Emirates, Greece, Qatar, Sweden and India (signed 20 February 2026 at the India AI Impact Summit), and on 26 March 2026 State announced a USD 250 million Pax Silica Fund intended to catalyse trusted-capital co-investment in critical-minerals processing and semiconductor supply chains.

The US Bureau of Industry and Security (BIS) amended the Export Administration Regulations to remove three foreign-owned semiconductor fabs operating in China — Intel Semiconductor (Dalian) Ltd, Samsung China Semiconductor Co. Ltd, and SK hynix Semiconductor (China) Ltd — from the Validated End-User (VEU) Authorizations list (15 CFR Part 748). BIS framed the VEU program as a "loophole" that previously allowed these fabs to receive most US-origin chipmaking equipment, software and technology license-free, a privilege no US-owned fab in China ever had. After the effective date, every restricted shipment to these fabs will require an individual export license, reviewed case-by-case under the existing 2022/2023 advanced- computing controls. The rule is published as Federal Register document 2025-16735 (90 FR 42321), Docket BIS-2025-0555, RIN 0694-AK32.

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 23 May 2025 the Bureau of Industry and Security notified major electronic design automation (EDA) suppliers — Cadence Design Systems, Synopsys, and Siemens EDA — by letter that a license is now required for any export, re-export, or in-country transfer of EDA software and technology classified under ECCNs 3D991 and 3E991 where a party to the transaction is located in China or is a Chinese "military end user" wherever located. BIS determined the shipments posed an unacceptable risk of diversion to Chinese military end use. The action was not published as a Federal Register rule; it surfaced publicly only through the affected companies' SEC 8-K disclosures. Synopsys suspended its FY2025 financial guidance in response. BIS rescinded the requirement effective 2 July 2025 (see amendments) amid the broader US-China trade truce, and the three vendors restored access for affected customers.

The US Bureau of Industry and Security amended the Export Administration Regulations to add 12 entities to the Entity List under the destinations of China (11) and Taiwan (1) via Final Rule 2025-05427 (90 FR 14046), companion to the larger 70-entity rule (2025-05426) published the same day. Targets fall in three clusters: (i) Beijing Academy of Artificial Intelligence and Beijing Innovation Wisdom Technology — added for acquiring US-origin items in support of China's military modernization, specifically developing large AI models and advanced computing chips for defense; (ii) the Inspur group — Inspur (Beijing) Electronic Information Industry, Inspur Electronic Information Industry, Inspur Electronic Information (Hong Kong), Inspur (HK) Electronics, Inspur Software, and Inspur Taiwan — added as subsidiaries contributing to supercomputers for military end use; and (iii) Henan Dingxin, Nettrix Information Industry, Suma Technology, and Suma-USI Electronics — added for involvement in the development of Chinese exascale supercomputers. License requirements are for all items subject to the EAR; review policy is presumption of denial for the AI cluster and policy of denial for the supercomputer clusters.

BIS (acting through its Office of Information and Communications Technology and Services, OICTS) published a final rule under Executive Order 13873's ICTS authority prohibiting certain connected-vehicle (CV) transactions involving hardware and software designed, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction of the People's Republic of China or the Russian Federation. The rule reaches the Vehicle Connectivity System (VCS — hardware/software enabling external RF connectivity above 450 MHz) and the Automated Driving System (ADS) software stack. Effective 17 March 2025, with phased prohibitions: import/sale of CVs incorporating covered software prohibited from model year 2027; import of covered VCS hardware prohibited from model year 2030 (or 1 January 2029 for hardware not associated with a model year). Importers and connected-vehicle manufacturers must file annual Declarations of Conformity.