Industrial Policy & Trade Monitor· 2662 actions· ✨ 89 recent

On 29 January 2026, the Council of the European Union adopted Council Implementing Regulation (EU) 2026/267 and the accompanying Council Decision, implementing the EU's Iran human-rights restrictive-measures regime (Regulation (EU) No 359/2011, in place since 2011 and renewed annually). The package designates 15 individuals and 6 entities over the violent repression of peaceful protests, arbitrary detention, and internet/media censorship in Iran, bringing the regime's cumulative total to 24 individuals and 26 entities. The six newly listed entities are the Iranian Audio-Visual Media Regulatory Authority (SATRA), the IRGC-linked Seraj Cyberspace Organization, the Working Group for Determining Instances of Criminal Content (WGDICC), Yaftar Pazhohan Pishtaz Rayanesh Limited Company, Douran Software Technologies, and Masaf Institute. Designated parties are subject to an EU-wide asset freeze and a prohibition on making funds or economic resources available to them; listed individuals additionally face a travel ban.

The US Treasury's Office of Foreign Assets Control designated 18 individuals and entities that make up the "rahbar" shadow-banking networks of sanctioned Iranian banks Bank Melli and Shahr Bank, including Singapore-based Golden Mist PTE Ltd, UAE-based Empire International Trading FZE and HMS Trading FZE, Iran-based Nikan Pezhvak Aria Kish Company and Tejarat Hermes Energy Qeshm, and UK-based Nanshan Ltd. Separately, OFAC designated senior Iranian security officials, including SCNS Secretary Ali Larijani, for their role in the regime's violent crackdown on peaceful protesters that began in December 2025. The financial designations were made under E.O. 13902 (Iran's financial/petroleum/petrochemical sectors) and the human-rights designations under E.O. 13553 and E.O. 13876, in furtherance of NSPM-2; Treasury noted it sanctioned more than 875 persons, vessels, and aircraft under the same maximum-pressure campaign in 2025.

On 20 May 2025, the Council of the European Union adopted the 17th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/932 amending Regulation 833/2014 (sectoral measures) and Council Implementing Regulation (EU) 2025/933 implementing Regulation 269/2014 (asset-freeze listings). Sectoral measures include the largest single-package expansion of the shadow-fleet port-access ban (additional vessel listings layered on top of the 153 designations carried over from the 16th package), the addition of 31 entities — including third-country (Chinese, Turkish, UAE, Hong Kong) firms — to the Annex IV list of military end-users barred from receiving dual-use and critical industry goods (covering chemical precursors used in missile propellants and spare parts for high-precision machine tools), and reinforced anti-circumvention "no-Russia" clause obligations on EU exporters. Council Implementing Regulation (EU) 2025/933 imposes asset freezes on 17 additional individuals and 58 additional entities, including shadow-fleet vessels and operators, a major Russian oil company, Russian military/defence-sector firms, and persons involved in the looting of Ukrainian cultural heritage. Parallel hybrid-threat, human-rights, and chemical-weapons designations were adopted under separate horizontal regimes on the same day. The Council noted EU shadow-fleet and oil-price-cap measures had reduced Russian revenues by approximately EUR 38 billion since introduction. Entry into force on 21 May 2025 (day following publication in the Official Journal).

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations by adding 8 entities to the Entity List under the destinations of Burma (2), China (2), and Russia (4), citing actions contrary to US foreign-policy interests, primarily enabling human-rights violations through aerial attacks on civilians (Burma), Uyghur surveillance (China), and facial-recognition targeting of protesters (Russia). All designated entities require licenses for all items subject to the EAR with a presumption of denial. The rule was effective immediately on publication, December 11, 2024.

Yacimientos de Litio Bolivianos (YLB), Bolivia's state lithium SOE, signed a contract in September 2024 with Uranium One Group — a subsidiary of Russia's Rosatom state nuclear corporation — for the design, construction, and initial operation of an industrial direct-lithium-extraction (DLE) carbonation plant at Salar de Uyuni, with initial capacity of 14,000 t/yr lithium carbonate (expandable to 25,000–45,000 t/yr), representing a total investment exceeding USD 970 million and a 51%/49% profit-split in Bolivia's favour. The contract was approved by Bolivia's Comisión de Economía Plural in February 2025 amid corruption allegations, then suspended by parliamentary motion on 14 February 2025; a Bolivian court issued a further precautionary suspension order on 27 May 2025 on human-rights, environmental, and Mother Earth rights grounds, while the Arce government continued to insist on legislative ratification through at least 29 May 2025.

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.

In a final rule effective December 9, 2021 (FR Doc 2021-26633), the Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to add Cambodia to Country Group D:5 (US arms-embargoed destinations), consistent with a simultaneous Department of State final rule adding Cambodia to ITAR §126.1. The rule also subjects Cambodia to military end-use (MEU) controls under EAR §744.21 and military-intelligence end-use/end-user (MIEU) controls under EAR §744.22. The stated rationale was deepening Chinese military presence at Ream Naval Base, growing corruption, and human-rights abuses by the Cambodian government.

Germany's Lieferkettensorgfaltspflichtengesetz (LkSG), promulgated 16 July 2021 (BGBl. I 2021 S. 2959), requires German-headquartered companies to conduct mandatory human-rights and environmental due diligence across their own operations and direct suppliers (with cause-based obligations extending to indirect suppliers). Enforced by BAFA with administrative fines up to EUR 8 million or 2% of global annual turnover for firms with revenue ≥ EUR 400 million. The act applies to ~3,000 German corporates from 1 January 2023 (≥3,000 employees) and was extended to ~5,000 firms from 1 January 2024 (≥1,000 employees). A September 2025 cabinet amendment removed the annual-reporting obligation and narrowed sanctionable omissions to serious violations.

The Bureau of Industry and Security amended the Export Administration Regulations by adding 34 entities under 43 entries to the Entity List, effective July 12, 2021. The largest cluster — 14 Chinese entities — comprises suppliers of surveillance infrastructure enabling the Chinese government's human-rights abuses in Xinjiang, including video analytics firms, network equipment makers, and geolocation platforms deployed in the Uyghur Region. Six Russian individuals and entities were added for participation in military procurement networks acquiring US-origin electronics and components in violation of the EAR. Additional listings cover Iran sanctions evaders (Canada, Lebanon), a UAE-based nuclear-proliferation facilitator, and one entity elevated from the Unverified List to the Entity List under China. All items subject to the EAR require a BIS licence to export, re-export, or transfer in-country to the listed parties, with a presumption-of-denial review policy.

Regulation (EU) 2021/821, adopted 20 May 2021 and applied from 9 September 2021, establishes the Union regime for controlling exports, brokering, technical assistance, transit, and transfer of dual-use items, repealing Regulation (EC) No 428/2009. Annex I lists controlled items implementing internationally agreed dual-use controls under the Wassenaar Arrangement, MTCR, Australia Group, NSG, and Chemical Weapons Convention. The regulation introduces a new catch-all control on cyber-surveillance technologies that could facilitate human-rights violations (Art. 5 and Annex IV), and strengthens cooperation between Member States and the European Commission, placing specific obligations on exporters. It serves as the statutory anchor for all EU export licences, every multilateral-regime transposition into EU law, and coordination mechanisms with US BIS, UK ECJU, JP METI, and KR MOTIE export-control regimes.

The Autonomous Sanctions Act 2011 (Cth Act No. 38 of 2011; assented 12 April 2011, commenced 6 December 2011 with the Autonomous Sanctions Regulations 2011) is Australia's foundational parent statute enabling the entire autonomous sanctions regime — economic and travel measures imposed unilaterally by Australia independently of UN Security Council mandatory obligations. The Minister for Foreign Affairs may, by legislative instrument, impose targeted financial sanctions, travel bans, and vessel-dealing prohibitions on designated persons, entities, and vessels. As of 2026 the Act underpins Australia's autonomous sanctions programs against Russia, Iran, DPRK, Myanmar, Belarus, Syria, Venezuela, Zimbabwe, Libya, Ukraine (occupied territories), and other regimes, and was materially extended in December 2021 to authorise Magnitsky-style thematic human-rights and corruption sanctions. Structurally peer-foundational to the UK Sanctions and Anti-Money Laundering Act 2018 (SAMLA), Canada's Special Economic Measures Act 1992 (SEMA), Japan's FEFTA sanctions provisions, and the EU's Anti-Coercion Instrument — the ASA 2011 completes the G7+AU sanctions-parent-statute set in the IPTM register.

Canada's Special Economic Measures Act (SEMA, S.C. 1992, c. 17; assented 4 June 1992) is the foundational umbrella statute enabling the entire Canadian autonomous sanctions regime — economic measures imposed by Canada independently of UN Security Council mandatory obligations. The Governor in Council may, on the recommendation of the Minister of Foreign Affairs, make regulations against a foreign state and its nationals or entities under four statutory triggers: (a) a grave breach of international peace and security causing or likely to cause a serious international crisis; (b) an international organisation or association of states to which Canada belongs has called for economic measures; (c) gross and systematic human-rights violations have been committed; or (d) acts of significant corruption by a foreign state's nationals or entities. As of the 2026-03-17 consolidation, 26 regulations are in force under SEMA targeting Russia, Ukraine (separatist entities), Iran, DPRK, Myanmar, Belarus, Syria, Venezuela, Zimbabwe, South Sudan, Libya, Haiti, Nicaragua, Moldova, and others — making SEMA the parent authority for the broadest multilateral-allied autonomous-sanctions toolkit outside the United States. Structurally peer-foundational to the UK Sanctions and Anti-Money Laundering Act 2018 (SAMLA), the CN Anti-Foreign Sanctions Law 2021, and Japan's FEFTA.