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

The Central Bank of Sudan (CBOS) issued Circular No. 12/2026 and Circular No. 13/2026 on 14 May 2026, restructuring Sudan's gold export regime. Circular 12/2026 abolished restrictions on exporters' use of gold and commodity export earnings — permitting proceeds to fund any Ministry of Trade-authorised import via an "intermediate import account" (21-day utilisation window) — and formally terminated the CBOS monopoly on gold purchases, allowing registered private traders to export through official channels. Circular 13/2026 established a daily gold incentive price (international 24-karat benchmark minus USD 10 per troy ounce, converted to USD per gram), published through the XAR electronic system; commercial banks and export-clearing authorities must clear shipments at or above this price.

On 6 November 2025, the US Department of the Interior (DOI) and the US Geological Survey (USGS) released the final 2025 List of Critical Minerals under the Energy Act of 2020 (30 U.S.C. § 1606), expanding the designation from 50 to 60 minerals. The final list adds 10 newly designated commodities — boron, copper, lead, metallurgical coal, phosphate, potash, rhenium, silicon, silver, and uranium — based on updated supply-chain disruption modelling, public comment, and interagency recommendations. The list constitutes the foundational statutory anchor for downstream US critical-minerals policy instruments including DPA Title III awards, DOE LPO Title 17 loan eligibility, IRA Section 45X Advanced Manufacturing Production Credit eligibility, Section 30D FEOC determinations, BIS export-control predicate assessments, Section 232 trade-investigation predicates, and CFIUS critical-technology triggers under 31 CFR § 800.215.

Regulation (EU) 2024/3015 of the European Parliament and of the Council of 27 November 2024 establishes the first EU-wide binding prohibition on placing, making available on, or exporting from the EU single market any products made with forced labour at any stage of production, manufacture, harvest, extraction or processing. The regulation is cross-sector and horizontal — no sectoral exemptions apply. It entered into force on 13 December 2024, with a phased implementation schedule; procedural and institutional framework provisions apply from 13 December 2024, while full operational application begins on 14 December 2027. The regulation empowers national competent authorities (and the Commission for state-imposed forced-labour cases involving third countries) to investigate, require withdrawal, and order destruction of non-compliant goods, and establishes a Commission-maintained publicly accessible database of high-risk geographic areas, sectors, and products.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register (89 FR 84472–84474, FR Doc 2024-24524) three general licenses issued under the Western Balkans Stabilization Regulations (31 CFR Part 588): GL 3A, GL 4, and GL 5. All three were originally issued on 18 June 2024 concurrent with OFAC's expansion of Republika Srpska / Dodik-network designations; the 23 October 2024 Federal Register notice formalises them per the Administrative Procedure Act notice requirements. GL 3A (which superseded GL 3 of 16 November 2023) authorises transactions involving certain WBSR-blocked entities that are ordinarily incident and necessary to the exportation or re-exportation of agricultural commodities, medicine, medical devices, replacement parts and components, software updates, or activities involving medical prevention, diagnosis, treatment, or clinical trials. GL 4 authorises wind-down transactions with entities blocked on 18 June 2024 through a defined cutoff. GL 5 authorises transactions ordinarily incident and necessary to the manufacture, distribution, operation, installation, or maintenance/repair of drinking-water pumps manufactured or distributed by the WBSR-blocked Bosnian Serb entity Kaldera Company EL PGP d.o.o. (and 50%-or-more-owned subsidiaries), preserving municipal water supply continuity.

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a final rule amending three sanctions programs. The rule adds a new general license at 31 CFR § 525.512 to the Burma Sanctions Regulations authorizing the provision of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, and software updates for medical devices to individuals whose property and interests in property are blocked. It also updates the authorities section of the Burma Sanctions Regulations to reflect recent legislation, replaces "the Office of Foreign Assets Control" / "the Director of the Office of Foreign Assets Control" with the acronym "OFAC" in three sections of the Sudan Stabilization Sanctions Regulations, and corrects a cross-reference in the Ukraine-/Russia- Related Sanctions Regulations. The rule is effective on publication.

Directive (EU) 2024/1760, adopted 13 June 2024 and entering into force 25 July 2024, imposes binding human-rights and environmental due-diligence obligations on large in-scope EU and non-EU companies across their chains of activities (upstream supply chain, own operations, and a limited part of downstream distribution). In-scope companies must identify, prevent, mitigate, and bring to an end actual and potential adverse human-rights and environmental impacts — covering forced labour, child labour, hazardous chemicals, and biodiversity loss — with obligations phased in from FY 2027 (EU companies with >5 000 employees and >EUR 1.5 bn turnover) through FY 2029 (>1 000 employees and >EUR 450 m). Companies must also adopt a climate transition plan compatible with the Paris Agreement 1.5 °C pathway (Art 22), and face civil liability for damages in national courts (Art 29); the original transposition deadline of 26 July 2026 was postponed and scope narrowed by the EU Omnibus I package (Directive 2026/470).

OFAC amended and reissued the Global Magnitsky Sanctions Regulations (31 CFR Part 583) in their entirety on 12 March 2024, to implement the Global Magnitsky Human Rights Accountability Act and EO 13818 (20 December 2017) more fully. The reissuance adds expanded interpretive guidance, new definitions (agricultural commodities, medicines, medical devices), new statutory authority (Uyghur Human Rights Policy Act of 2020), and several new general licenses covering blocked-account management, legal services, personal-use medical/food transactions, and emergency services. No new SDN designations or country-level targeting; the action is a compliance-architecture update that clarifies permissible conduct and tightens procedural standards across the global human-rights-and-corruption sanctions program.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register (89 FR 16400, FR Doc 2024-04856) two general licenses issued under the Western Balkans Stabilization Regulations (31 CFR Part 588): GL 2 and GL 3. Both were originally issued on 16 November 2023 concurrent with OFAC's initial round of Republika Srpska / Dodik-network designations; the 7 March 2024 Federal Register notice formalises them per the Administrative Procedure Act notice requirements. GL 2 authorises wind-down transactions with newly blocked WBSR entities through 15 March 2024. GL 3 authorises exports and re-exports of agricultural commodities, medicine, medical devices, replacement parts, and services for medical prevention and treatment to WBSR-blocked persons; GL 3 was subsequently superseded by GL 3A on 18 June 2024.

Regulation (EU) 2023/1115, adopted 31 May 2023 and in force 29 June 2023, requires all EU operators and traders placing seven in-scope commodities and their derived products on the EU market — or exporting them from the EU — to file due-diligence statements certifying that goods are deforestation-free (no land cleared after 31 December 2020) and produced in compliance with the relevant legislation of the country of origin. A Commission-administered risk-classification system assigns producer countries to low, standard, or high-risk tiers with differentiated due-diligence burdens. Application was subsequently postponed twice: to 30 December 2026 for large operators (Reg (EU) 2024/3234 and Reg (EU) 2025/2650).

Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (S.C. 2023, c. 9; "Bill S-211") received Royal Assent on 11 May 2023 and entered into force on 1 January 2024. It imposes a binding annual supply-chain disclosure obligation on government institutions and in-scope private-sector entities (any two of: ≥CAD 20m assets, ≥CAD 40m revenue, ≥250 employees) requiring a public report by 31 May each year detailing steps taken to prevent and reduce the risk of forced or child labour in their supply chains. The Act also amends the Canadian Customs Tariff (Schedule 9898.00.00) to extend the existing import prohibition on goods produced with forced labour to also cover goods produced with child labour, enforced at the border by the Canada Border Services Agency (CBSA). Criminal penalties of up to CAD 250,000 apply for non-compliance, false reporting, or obstruction.

Loi n° 2014-138, adopted by the Assemblée nationale and promulgated by President Alassane Ouattara on 24 March 2014, is the foundational mining-rights statute governing all mineral prospecting, research, and exploitation in Côte d'Ivoire. Its 197 articles across 16 titles repeal the prior Loi n° 95-553 (1995 Code Minier) and establish the modern permit regime, a 10% state free-carry in all industrial mining projects via SODEMI, and the royalty + ad valorem fiscal architecture that underpins every subsequent mining-convention and fiscal-law amendment. As West Africa's second-largest gold producer (approx. 45 t/yr) with growing bauxite and manganese exploration, CI's mining-code architecture is a material determinant of supply-chain access for Western and Chinese industrial consumers of these commodities.