Industrial Policy & Trade Monitor· 2665 actions· ✨ 90 recent

On 26 May 2026 the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, imposed a £1,000,920.59 monetary penalty on Sabre Global Technologies Limited (SGTL), a UK-registered travel-technology firm, for repeated breaches of UK financial sanctions. SGTL continued to provide Russian carrier Ural Airlines access to its Global Distribution System (GDS) service for seven months after Ural Airlines was designated by the UK in May 2022, and during July–August 2022 actively explored routing payments through a US bank account to avoid detection by its UK bank — the conduct that makes this the **first OFSI penalty issued for a circumvention offence**. At £1,000,921 this is also OFSI's **largest financial-sanctions penalty since Russia's 2022 invasion of Ukraine**, surpassing the prior record (HSF £465k).

On 25 February 2026 the Swiss Federal Council adopted extensive amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (Ukraine Ordinance) and the Ordinance on Measures against Belarus, completing implementation of the EU's 19th sanctions package with effect from 26 February 2026. Headline measures: a complete ban on the purchase and import of Russian LNG taking effect 25 April 2026 (transition period until end-2026 for pre-existing long-term contracts); a complete prohibition on the provision of crypto-asset services to Russian persons and companies; new service bans covering advanced-technology / AI / high-performance-computing services and tourism-related services; expansion of the dual-use end-user list (Annex 2) including additional Chinese entities; SECO authority to grant divestment-exemption licences until end-2026 under Art. 30a; and parallel adoption of the EU October 2025 Belarus measures via amendment to the Belarus Ordinance.

Ukrainian President Volodymyr Zelenskyy signed Decree No. 102/2026 on 7 February 2026, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 27 legal entities: 22 based in Russia and 5 based in China and Hong Kong. The designees are described as active in defense manufacturing, precision engineering, optics, electronics, aerospace, and applied research, technology and banking/trading activity that Ukraine assesses as supporting Russian weapons production and its financing. The decree entered into force on 10 February 2026.

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.

The UK Foreign, Commonwealth & Development Office designated two China-based commercial cyber companies — Sichuan Anxun Information Technology Co Ltd (known as i-Soon) and Integrity Technology Group Incorporated — under the UK's Cyber sanctions regime, freezing their UK assets and imposing controls on commercial transactions and investment instruments involving them. i-Soon was designated for targeting over 80 government and private-sector IT systems worldwide, including UK public-sector and private-industry networks. Integrity Tech was designated for operating a covert botnet of more than 260,000 compromised devices globally and supplying access to it to enable unauthorised intrusion into UK public-sector systems.

On 19 November 2025, the U.S. Treasury's Office of Foreign Assets Control (OFAC), in a coordinated action with Australia's Department of Foreign Affairs and Trade and the UK's Foreign, Commonwealth and Development Office, designated 5 individuals and 7 companies linked to two Russia-based "bulletproof hosting" (BPH) providers, Media Land and Aeza Group, under Executive Order 13694. Media Land and its subsidiaries (Media Land Technology, Data Center Kirishi, ML Cloud) supplied server infrastructure to ransomware groups including LockBit, BlackSuit and Play. The designations also targeted three companies Aeza Group used to evade its July 2025 OFAC designation and rebrand its infrastructure: Hypercore Ltd. (United Kingdom), Smart Digital Ideas DOO (Serbia), and Datavice MCHJ (Uzbekistan). All designated persons' U.S.-nexus assets are blocked and U.S. persons are prohibited from transacting with them.

The US Treasury's Office of Foreign Assets Control designated a Russian national (Vitaliy Sergeyevich Andreyev), a Russia-based DPRK economic and trade consular official (Kim Ung Sun), a Chinese front company (Shenyang Geumpungri Network Technology Co., Ltd), and a DPRK trading company subordinate to the DPRK Ministry of People's Armed Forces General Political Bureau (Korea Sinjin Trading Corporation) for facilitating a fraudulent overseas IT-worker scheme that funds North Korea's weapons of mass destruction and ballistic missile programs. The action expands on the prior designation of Chinyong Information Technology Cooperation Company, an entity tied to the DPRK defense ministry that deploys IT worker delegations in Russia and Laos. Treasury said Andreyev and Kim Ung Sun facilitated cryptocurrency-to-cash conversions worth nearly USD 600,000 since December 2024, and that Shenyang Geumpungri's delegation of DPRK IT workers has earned Chinyong and Sinjin over USD 1 million in profits since 2021. Designations were made under Executive Order 13687, blocking all US-jurisdiction property of the four parties and barring US persons from transactions with them.

On 16 August 2025, Ukraine's President signed Decree No. 599/2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 39 individuals and 55 legal entities identified as involved in developing, manufacturing, or supplying components for Russian unmanned aerial vehicles (UAVs) with artificial-intelligence elements. The list covers 43 Russian entities (including drone makers Prognatik, Rozumni Ptakhy, Zala Aero, and KB Vostok, plus AI research centres Neurolab and TsBST), 10 Chinese suppliers of navigation receivers, engines, cameras, and microchips (including Dongguan Standard Trading, Zhejiang Lianxing Machinery, Shenzhen Sky Bow Navigation Technology, and Topscom Precision Industry), and 2 Belarusian component suppliers. Sanctions impose asset freezes and restrictions on commercial transactions and investment instruments, entered into force immediately upon signature and revocable no later than 15 August 2035.

The US Treasury's Office of Foreign Assets Control designated the Korea Sobaeksu Trading Company (also known as Sobaeksu United Corporation) and three associated individuals — Kim Se Un, Jo Kyong Hun, and Myong Chol Min — for evading US and UN sanctions and clandestinely generating revenue for the DPRK government, including through fraudulent information-technology worker schemes. Sobaeksu operates as a front company for the US-designated Munitions Industry Department, which oversees North Korea's nuclear program and ballistic-missile development. The action was coordinated with a Department of Justice unsealing of indictments against seven DPRK nationals over counterfeit- cigarette sanctions evasion, and State Department reward offers of up to USD 7 million for information on the individuals involved. Designations block all US-jurisdiction property of the four parties and bar US persons from transacting with them.

Canada made SOR/2025-143, Regulations Amending the Special Economic Measures (Russia) Regulations, registered 2025-06-13. The regulations add 14 new items (743-756) to Part 2 of Schedule 1, designating Russian quantum-technology institutions and firms — including the Moscow State University Quantum Technology Centre, the National University of Science and Technology's Centre for Quantum Communications, QRate, and Rusnano — triggering a dealings ban and asset freeze. The same instrument adds a new import prohibition on coal products (Schedule 5.01) and a new export prohibition on jet fuel and additives (Schedule 5.02) and on chemical/ biological-weapons-related items (Schedule 10.1), and extends the existing metals import ban (Schedule 11) to further product lines — all coming into force 60 days after registration (~2025-08-12), with a 120-day grace period for pre-existing contracts.

China's MOFCOM Unreliable Entity List Working Mechanism designated six US firms on 9 April 2025, effective 12:01 Beijing time 10 April 2025, under MOFCOM Order No. 4 of 2020. Cited trigger: participation in arms sales to Taiwan or military-technology cooperation with Taiwan in disregard of China's stated opposition, "seriously harming China's national sovereignty, security and development interests." Measures prohibit the six entities from import/export activities related to China, new investments in China, and impose entry/work-permit restrictions on senior management.

China's MOFCOM Unreliable Entity List Working Mechanism designated 11 US drone-sector companies on 4 April 2025 — Skydio Inc., BRINC Drones Inc., Kratos Unmanned Aerial Systems Inc., Insitu Inc., Red Six Solutions LLC, SYNEXXUS Inc., Firestorm Labs Inc., HavocAI, Neros Technologies, Domo Tactical Communications LLC, and Rapid Flight LLC — citing military-technology cooperation with Taiwan in violation of China's One-China principle. Designations prohibit the 11 firms from import/export activity related to China, bar new investments in China, and restrict senior-executive entry. Issued on the same date as the MOFCOM heavy rare-earth export-licensing measure, the designations formed a paired retaliation package responding to the 2 April 2025 US "Liberation Day" reciprocal-tariff escalation. On 15 May 2025 MOFCOM suspended the UEL restrictions on all 11 companies for 90 days in line with the US-China Geneva tariff truce.

China's Unreliable Entity List (UEL) Working Mechanism, led by MOFCOM, issued Announcement [2025] No. 2 on 4 February 2025, designating PVH Group (parent of Calvin Klein and Tommy Hilfiger) and Illumina Inc. (US genomics / gene-sequencing equipment maker) as Unreliable Entities under the 2020 UEL Provisions, citing violations of normal market-transaction principles and discriminatory measures against Chinese enterprises. PVH was cited for its Xinjiang-cotton sourcing boycott (MOFCOM probe launched September 2024); Illumina was cited for restricting Chinese customers' access to gene-sequencing equipment. The announcement was issued on the same day as China's IEEPA-retaliation tariff package (10–15 % on US coal, LNG, crude oil, agricultural goods, and autos), making it the first UEL listing of a Western consumer-brand / retail company and the first combining a UEL designation with a subsequent sector-specific export prohibition (gene sequencers, imposed 28 February 2025).

China's Unreliable Entity List Working Mechanism, led by MOFCOM, issued Announcement [2025] No. 1 on 2 January 2025 designating 10 US defense entities — five Lockheed Martin subsidiaries (Missiles and Fire Control, Aeronautics, Missile System Integration Lab, Advanced Technology Laboratories, Ventures), the Javelin Joint Venture (Raytheon/Lockheed Martin), Raytheon Missile Systems, and three General Dynamics units (Ordnance and Tactical Systems, Information Technology, Mission Systems) — as Unreliable Entities under the 19 September 2020 Provisions on the Unreliable Entity List, citing their participation in US arms sales to Taiwan. The measures prohibit the 10 firms from engaging in import/export activity related to China and from making new investments in China, and bar approval/renewal of work permits and stay/residence qualifications for their senior executives. This is the first multi-entity UEL designation under the 2020 Provisions and was issued the same day as the parallel MOFCOM Announcement [2025] No. 1 of the export-control bureau adding 28 US entities to China's Export Control List — together establishing a coordinated two-track countermeasure template against US defense and dual-use industry.

The Council of the EU adopted Implementing Regulation (EU) 2024/2697, implementing Regulation (EU) 2023/1529 concerning restrictive measures in view of Iran's military support to Russia's war of aggression against Ukraine. The listing adds 7 individuals and 7 legal entities to the EU asset freeze. The entities include three Iranian state and private airlines (Saha Airlines, Mahan Air, Iran Air) named as repeat carriers of Iranian-made UAVs and related technology to Russia, a UAV-procurement network (Basamad Electronic Pouya Engineering Co., Teyf Tadbir Engineering Company) run through EU-listed businessman Hossein Hatefi Ardakani, and two entities tied to Iran's ballistic-missile programme: Iran Alumina Company (IAC), Iran's sole producer of alumina powder used in solid rocket-fuel propellant, and Shahid Haj Ali Movahed Research Center, a missile R&D subsidiary of the EU-listed Shahid Hemmat Industries Group. All funds and economic resources of the listed parties are frozen within the EU, and EU persons/entities are barred from making funds available to them.

On 29 June 2024 the Council of the European Union adopted Council Regulation (EU) 2024/1865 and Council Decision (CFSP) 2024/1864, amending Regulation (EC) No 765/2006 to extend Belarus's sanctions regime so that it mirrors the restrictive measures already in force against Russia, closing routes used to circumvent the Russia sanctions via Belarus. The package bans the import of gold, diamonds, helium, coal and other mineral products (including crude oil) originating in or exported from Belarus; bans the import of goods and technology on the EU Common Military List if of Belarusian origin; extends the export ban on dual-use goods, oil-refining and LNG-liquefaction equipment, maritime-navigation goods and luxury goods to Belarus; prohibits transit via Belarus of EU-exported firearms and ammunition; and broadens the road-transport ban. The measures entered into force on 1 July 2024, the day after publication in the Official Journal.

On 29 February 2024 Switzerland's WBF decided to align with the EU's 13th Russia sanctions package by amending the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), effective 1 March 2024 at 18:00 CET. The amendment adds over 100 individuals and nearly 90 entities — mainly Russian military-industrial-complex firms and suppliers of DPRK-sourced weapons to Russia — to the asset-freeze and designation lists, and extends the dual-use/military-technology export ban to 27 additional companies believed to be circumventing existing controls.

On 23 February 2024, two years after Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Council Regulation (EU) 2024/745, amending Regulation (EU) No 833/2014 and comprising the EU's 13th Russia sanctions package. It adds new CN codes to the export-ban annexes (dual-use and advanced-technology goods) and adds 27 entities — including firms based in China, Hong Kong, India, Sri Lanka, Serbia, Kazakhstan, Thailand and Turkiye — to the list of parties barred from any exemption from the export ban, on the basis they are assessed to be supporting Russia's military-industrial complex via circumvention routes. Asset-freeze listings (106 individuals, 88 entities) under the parallel Council Decision took effect 23 February 2024; the sectoral trade measures took effect 24 February 2024.

On 18 October 2023 the Governor in Council registered Regulations Amending the Special Economic Measures (Iran) Regulations (SOR/2023-220) under the Special Economic Measures Act, citing Iran's proliferation- sensitive nuclear activities and weapons-of-mass-destruction-related programme as a grave breach of international peace and security. The amendment prohibits Canadians and Canadian entities from exporting, selling or supplying to Iran dual-use goods and technology, conventional arms (battle tanks, armoured combat vehicles, large-calibre artillery, combat aircraft, attack helicopters, warships), Missile Technology Control Regime-listed equipment, and technical data related to ballistic missiles and nuclear-weapon delivery systems; it also bars importing arms and related material from Iran. The same instrument adds 156 entities and 18 individuals to Canada's Iran sanctions list (asset freeze / dealings prohibition).

Poland's Minister of Development and Technology, Waldemar Buda, established a temporary compulsory administrator (tymczasowy zarządca przymusowy) over the Grupa Azoty S.A. shares held by sanctioned Russian oligarch Vyacheslav Kantor through three holding vehicles — Norica Holding S.à r.l. (Luxembourg), Opansa Enterprises Limited and Rainbee Holdings Limited (both Cyprus) — which together controlled 19.82% of the state-linked fertiliser and chemicals group, worth over PLN 0.5bn. The ministry cited Kantor's inclusion on Poland's sanctions list and the protection of the country's economic and energy security, and stated its intent to find a buyer for the stake and compensate Kantor. The Provincial Administrative Court in Warsaw (WSA) later overturned the decision establishing the administration; the ministry did not appeal, and the ruling became final around 30 July 2024, ending the administrator's mandate — though the underlying EU/Polish sanctions on Kantor continue to freeze his ability to exercise any rights attached to the shares.

On 23 June 2023 the Council of the European Union adopted Council Regulation (EU) 2023/1214, amending Regulation (EU) No 833/2014 and comprising the EU's 11th Russia sanctions package. It extends the list of goods generating significant revenue for Russia subject to import bans, adds further export-ban categories (including additional industrial goods, dual-use and advanced-technology items), and introduces a new anti-circumvention tool (Article 12g) allowing the EU to restrict exports of specified sanctioned goods and technology to third countries assessed as high-risk transshipment routes for Russia. Asset-freeze listings under the parallel Council Decision took effect 23 June 2023; the sectoral trade measures took effect 24 June 2023.

On 25 February 2023, one year into Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Council Regulation (EU) 2023/427, the 10th package of sanctions, amending Regulation (EU) 833/2014. It entered into force on publication the following day (26 February 2023). The package bans imports of asphalt and synthetic rubber from Russia (with a temporary transitional import quota for rubber products running to 30 June 2024), expands the export ban on dual-use and advanced-technology goods, suspends further Russian media broadcasting licences in the EU, and designates 87 individuals and 34 entities — including Iranian persons and entities involved in drone manufacture and supply, and 96 entities tied to Russia's defence-industrial base — to the EU asset-freeze/travel-ban list.

On 24 February 2023, the first anniversary of Russia's full-scale invasion of Ukraine, the US Department of State announced a package of sanctions designations under the executive order blocking property of persons engaged in harmful foreign activities of the Russian government (E.O. 14024). The State Department describes designating over 60 individuals and entities, including Russian officials and entities in Russia's advanced-technology sector, three enterprises that develop and operate Russia's nuclear weapons, and three civil nuclear entities within the Rosatom structure. The Treasury Department announced parallel designations, including four entities in the metals and mining sector.

Switzerland's Federal Council amended the Ordinance on measures related to the situation in Ukraine (SR 946.231.176.72) to align with the EU's ninth sanctions package, effective 6pm on 25 January 2023. The amendment bans new Swiss investment, equity provision, and participation (including joint ventures) in Russian mining-sector entities, with a carve-out for critical raw materials (aluminium/bauxite, chromium, cobalt, copper, iron ore, mineral fertilisers, molybdenum, nickel, palladium, rhodium, scandium, titanium, vanadium). It also extends export bans on aerospace goods to aircraft and drone engines, adds new controls on dual-use and military/security-enhancement goods, bans product testing/advertising/market-research services to Russia, and designates roughly 200 additional individuals and entities, including the Russian Regional Development Bank, to frozen-asset lists.

On 16 December 2022 the Council of the European Union adopted Council Regulation (EU) 2022/2474, the 9th package of restrictive measures against Russia, amending Regulation (EU) 833/2014. It entered into force on publication the following day (17 December 2022). The package extends the prohibition on new EU investment from the Russian energy sector to the Russian mining and quarrying sector, bans exports of aircraft and drone engines and their parts to Russia (and to any third country that could re-supply drones to Russia), adds 168 entities to the sectoral export- control annex covering chemicals, nerve agents, night-vision and radio- navigation equipment, electronics and IT components, and prohibits EU advertising, market-research, product-testing and technical-inspection services to Russia. A parallel Council Decision/Implementing Regulation designated a further 141 individuals and 49 entities to the EU asset-freeze and travel-ban list.

On 19 October 2022, the US Treasury's Office of Foreign Assets Control (OFAC) designated Russian national Yury Yuryevich Orekhov, resident in Dubai, UAE, under Executive Order 14024 for operating a network that procured military and sensitive dual-use technology from Western suppliers for Russian end-users. Two entities tied to Orekhov were designated alongside him: NDA Nord-Deutsche Industrieanlagenbau GmbH, based in Hamburg, Germany, and Opus Energy Trading LLC, based in Dubai, UAE. The designation blocks all US property and interests of the designated persons and generally prohibits US persons from transacting with them.

OFAC reissued the Cyber-Related Sanctions Regulations (31 CFR Part 578) in their entirety on 6 September 2022, replacing the abbreviated placeholder framework first published on 31 December 2015. The reissuance implements Executive Order 13694 (1 April 2015, blocking property of persons engaging in significant malicious cyber-enabled activities) and Executive Order 13757 (28 December 2016, expanding that authority to include election interference). The full-form regulations add interpretive definitions, general licences, and civil-penalties provisions — providing compliance clarity for US financial institutions and technology companies without expanding the underlying sanctions perimeter.

The UK laid the Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 (UKSI 2022/748), in force 5 July 2022, extending the Belarus sanctions regime to mirror measures already imposed on Russia over the invasion of Ukraine. The regulations ban export to Belarus of dual-use goods and technology for all purposes, and of critical-industry goods and technology including quantum-computing components, microelectronics, marine and navigation equipment, and aircraft/aircraft parts. They widen existing import bans to cover a greater range of petroleum/mineral products and prohibit import of arms, iron and steel products originating in or consigned from Belarus, and extend financial sanctions barring Belarusian companies from issuing debt or securities in London or obtaining loans from UK banks, and barring UK persons from providing financial services to the National Bank of the Republic of Belarus or the Belarusian Ministry of Finance.

On 1 March 2022, OFAC published an interim final rule adding the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR) at 31 CFR Part 587, codifying into Title 31 of the Code of Federal Regulations all prohibitions previously imposed by Executive Order 14024 of 15 April 2021. The regulations were issued in abbreviated form to provide immediate public guidance, with OFAC indicating an intent to supplement them with additional definitions, general licenses, and interpretive guidance. All transactions prohibited under EO 14024 — including prior sectoral determinations and directives targeting Russia's financial services sector, sovereign debt markets, and key state institutions — are formally prohibited under Part 587, giving domestic courts and compliance teams a stable regulatory anchor.

Council Regulation (EU) 2022/263 prohibits importing into the EU any goods originating in the non-government-controlled areas of Ukraine's Donetsk and Luhansk oblasts, and bans the sale, supply, transfer or export of Annex II goods and technology (transport, telecommunications, energy, resource extraction) to those areas. It also bars new investment and financing there. It entered into force the day after adoption, 24 February 2022.

Executive Order 14065, signed 21 February 2022, prohibits new investment by US persons in the so-called Donetsk and Luhansk People's Republic (DNR/LNR) regions of Ukraine, bans the importation into the United States of any goods, services or technology from those Covered Regions, and bans exports, reexports, sales or supply to them by or from US persons. It also prohibits US-person approval, financing, facilitation or guarantee of transactions by foreign persons that would be barred if done by a US person. It expands the national emergency first declared in EO 13660.

OFAC codified the Chinese Military-Industrial Complex Sanctions Regulations at 31 CFR Part 586, implementing Executive Order 13959 (November 12, 2020) as amended by Executive Order 14032 (June 3, 2021). The regulations prohibit US persons from purchasing or selling publicly traded securities of entities designated on OFAC's Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List, which identifies firms determined to support the People's Liberation Army or Chinese surveillance-technology programs. A divestment deadline of June 3, 2022 applied to entities named in the original EO 13959 annexes; future additions carry a one-year divestment window from the date of designation.