Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

OFAC published an interim final rule creating 31 CFR Part 599 to implement Executive Order 14059 (December 15, 2021), which declared a national emergency regarding the unusual and extraordinary threat posed by the global illicit drug trade, including fentanyl and synthetic opioid trafficking. The regulations establish blocking prohibitions, SDN List designation procedures, and enforcement mechanisms targeting foreign persons who materially contribute to international drug proliferation. OFAC stated it would supplement this interim rule with more comprehensive final regulations covering licensing, reporting, and penalty procedures.

On 20–21 December 2022 OFAC published two final rules (87 FR 78470 and 87 FR 78484) amending regulations across more than 30 sanctions programs to add general licenses (GLs) authorising four categories of humanitarian activity: (1) certain NGO transactions for disaster relief, health, democracy support, education, environmental protection, and peacebuilding; (2) provision of agricultural commodities, medicine, medical devices, replacement parts, and software updates for medical devices to blocked persons for personal, non-commercial use; (3) US government official-business transactions; and (4) official-business transactions of designated international organisations (e.g. UN, ICRC). The rules amended 29 CFR parts spanning Nicaragua, Iraq, Somalia, South Sudan, Yemen, and more than two dozen other sanctioned programs. The NGO GL excludes knowing fund transfers to blocked persons unless specified criteria are met, preserving the core blocking perimeter while lowering humanitarian-access friction.

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.

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.

Switzerland's Federal Council amended the Ordinance on measures in connection with the situation in Ukraine (SR 946.231.176.72) to align with the EU's eighth sanctions package, effective 6pm on 23 November 2022. The amendment creates the Swiss legal basis for an oil price-cap mechanism — banning maritime transport to third countries of Russian-origin crude oil and petroleum products unless purchased at or below a price cap to be set later (the G7/EU $60/bbl cap followed on 3 December 2022; see the companion US OFAC determination of 2022-12-05). It also extends import/export restrictions to additional iron and steel products and aerospace goods, bans the provision of IT, engineering, architecture and legal services to the Russian government and Russian companies, bans Swiss nationals from holding board seats at certain Russian state-owned companies, fully bans crypto-asset wallet/account/custody services to Russian persons regardless of value, and adopts an arms embargo against Russia (extended in part to Ukraine for reasons of Swiss neutrality).

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.

On 6 October 2022 the Council of the European Union adopted Council Regulation (EU) 2022/1904, amending Regulation (EU) No 833/2014, as the EU's eighth package of restrictive measures against Russia. It entered into force 7 October 2022. The regulation's headline measure creates the legal basis for an oil price-cap mechanism: a ban on maritime transport to third countries of Russian-origin crude oil and petroleum products, becoming operational once the Council sets an actual cap level by a separate decision (the G7/EU $60/bbl cap followed on 3 December 2022). The package also expands import bans on steel products (phased through 2024), firearms and ammunition, wood pulp and paper, and certain chemicals, cosmetics and jewellery materials; extends export bans on aviation-sector goods; bans the provision of architectural, engineering, IT-consultancy and legal advisory services to the Russian government and Russian companies; and imposes restrictions on Russian-flagged vessels at the Russian Maritime Register.

Council Regulation (EU) 2022/1903 amends Regulation (EU) 2022/263 so that its import ban and export restrictions, previously limited to the non-government-controlled areas of Donetsk and Luhansk, also cover the non-government-controlled areas of Ukraine's Kherson and Zaporizhzhia oblasts. It was adopted on 6 October 2022 alongside the eighth Russia sanctions package and entered into force the day after publication in the Official Journal.

OFAC reissued the Central African Republic Sanctions Regulations (31 CFR Part 553) in their entirety on 29 September 2022, replacing the abbreviated framework first published on 7 July 2014 under Executive Order 13667. The reissuance adds interpretive guidance, definitions, and general licenses — including provisions for humanitarian assistance, personal communications, and non-commercial personal remittances — without expanding the underlying substantive sanctions perimeter. The action is primarily a regulatory codification that provides compliance clarity for financial institutions and other US persons transacting with or near CAR.

OFAC reissued the Western Balkans Stabilization Regulations (31 CFR Part 588) in their entirety on 29 September 2022, updating the framework that implements Executive Orders 13219 (2001), 13304 (2003), and 14033 (2021). The reissuance added three new definitions, expanded interpretive guidance, incorporated three new general licenses, and explicitly operationalised E.O. 14033's expanded emergency — which extended the Western Balkans sanctions perimeter to cover corruption and anti-democratic destabilisation, not just armed-conflict threats. The regulations apply to persons in or linked to the territory of the former Socialist Federal Republic of Yugoslavia and the Republic of Albania.

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.

On 4 August 2022 OFAC formally published in the Federal Register nine general licenses (GLs 17–25) that had previously been made available only on OFAC's website under EO 14065 (Donetsk/Luhansk regions) and, for GL 25, also EO 13685 (Crimea). GL 17, which authorised wind-down of Donetsk/Luhansk transactions, had already expired on 23 March 2022. GLs 18–25 remain in force and authorise a structured set of humanitarian and civil-society carve-outs — covering agricultural commodities, medicine and medical devices, telecommunications, official international organisation business, personal remittances, internet-based communications, NGO activities, civil maritime services, and journalistic activities — within the otherwise restricted territory of Crimea, the so-called Donetsk People's Republic (DNR), and the Luhansk People's Republic (LNR).

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.

OFAC adopted a final rule on 1 July 2022 amending the Global Terrorism Sanctions Regulations (GTSR, 31 CFR Part 594) to implement Executive Order 13886 ("Modernizing Sanctions To Combat Terrorism," 9 September 2019). The rule expands the designation criteria in §594.201 to reflect EO 13886's additions, allowing OFAC to block property of foreign persons who act on behalf of, or provide material support to, foreign terrorist organizations (FTOs) — broadening the perimeter beyond EO 13224's original focus on persons threatening international peace and stability through terrorism. Supporting amendments update cross-references and the definition of "effective date" throughout Part 594 to reflect the new authority baseline.

The Council of the EU adopted Council Implementing Regulation (EU) 2022/878 of 3 June 2022, implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. The regulation adds 65 individuals and 18 legal entities to Annex I, subjecting them to an EU-wide asset freeze and a prohibition on EU persons or entities making funds or economic resources available to them. The listed entities span Russia's defense-industrial base, military-linked vehicle and tyre manufacturing, and financial-market infrastructure.

On 3 June 2022 the Council of the European Union adopted Regulation (EU) 2022/879, the sixth package of sanctions against Russia over the invasion of Ukraine, further amending Regulation (EU) No 833/2014. It bans the seaborne import of Russian crude oil and refined petroleum products, covering roughly two-thirds of EU oil imports from Russia at adoption (pipeline deliveries via Druzhba were temporarily exempted). It removes Sberbank, Credit Bank of Moscow and Russian Agricultural Bank from SWIFT (Annex XIV), bans EU operators from providing accounting, auditing, bookkeeping, tax consulting, business/management consulting and public-relations services to persons in Russia (new Article 5n), and adds three more Russian broadcasters to the EU broadcasting-suspension list (Annex XV). It entered into force on 4 June 2022, the day after publication in the Official Journal.

OFAC final rule (FR Doc 2022-12445, 87 FR 35068) amending the Cuban Assets Control Regulations at 31 CFR Part 515 to implement elements of the Biden administration's May 16, 2022 Cuba policy announcement supporting the Cuban people. The rule reinstates the group people-to-people educational travel general license (suspended under the Trump administration) for organizations sponsoring exchanges that promote meaningful contact with Cubans and support civil society; removes the $1,000 quarterly limit on family remittances to close relatives in Cuba; authorizes donative remittances to Cuban nationals not affiliated with the government or Communist Party; and expands authorizations for professional meetings and conferences in Cuba. Effective June 9, 2022.

Canada registered SOR/2022-98, Regulations Amending the Special Economic Measures (Russia) Regulations, on 6 May 2022, adding five Russian defence-sector entities to Schedule 1 of the regulations: Zelenodolsk Shipyard JSC, Military Industrial Company LLC, Rosgvardia, UEC Klimov JSC and KAMAZ PTC. The listing triggers Canada's standard dealing/asset-freeze prohibitions against the named entities under the Special Economic Measures Act, part of Canada's ongoing sanctions response to Russia's February 2022 invasion of Ukraine.

On 2 May 2022 OFAC published a comprehensive final rule in the Federal Register renaming the Ukraine Related Sanctions Regulations (31 CFR Part 589) to the Ukraine-/Russia-Related Sanctions Regulations and replacing the abbreviated regulatory text that had been in place since 2014 with a fully elaborated framework. The new Part 589 incorporates interpretive guidance, definitional provisions, and consolidated general licenses implementing Executive Orders 13660, 13661, and 13662 — the original March 2014 Ukraine/Crimea-crisis authorities. The rule does not introduce new substantive prohibitions; it formalises and makes accessible the regulatory infrastructure that underlies subsequent GL issuances (e.g., GL 13Q/13R, GL 15K/15L) and OFAC designation actions under the Ukraine-/Russia-Related Sanctions program.

On 21 April 2022 the UK announced import bans on Russian silver, wood products and other high-value goods (incl. caviar), alongside a 35-point tariff increase on selected Russian and Belarusian goods. The ban was legislated by the Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 (SI 2022/689, made 20 June, in force 23 June 2022), which inserted a new Schedule 3D ("revenue generating goods") and prohibitions 46T-46W: import of Schedule 3D goods originating in or consigned from Russia, their acquisition, supply/delivery into the UK and related technical assistance are prohibited, subject to Part 7 exceptions and licences. Schedule 3D covers all of HS chapter 44 (wood and articles of wood; wood charcoal), HS 7106 silver, plus e.g. caviar, cement, potassium chloride and NPK fertilisers, pulp and kraft paper, glass, and aluminium plate.

On 8 April 2022 the Council of the European Union adopted Regulation (EU) 2022/576, further amending Regulation (EU) No 833/2014 (the fifth package of measures against Russia). It bans imports of Russian coal and other solid fossil fuels, wood, cement, rubber, fertilisers, high-end seafood and spirits; bans exports to Russia of jet fuel, quantum computers, advanced semiconductors, high-end electronics and sensitive machinery; bars Russian and Belarusian road-freight operators from EU territory; and closes EU ports to Russian-flagged vessels. It entered into force on 9 April 2022, the day after publication in the Official Journal (OJ L 111).

On 16 March 2022 the Swiss Federal Council adopted a total revision of the Ordinance on Measures against Belarus (SR 946.231.116.9), aligning Switzerland's autonomous sanctions with the EU's Belarus regime. It bans imports of Belarusian petroleum products, potassium chloride ("potash"), wood, iron and steel, and cement and rubber products; bans exports of goods used to manufacture or process tobacco products, weapons, surveillance equipment, and goods usable for Belarus's military or security development; and imposes financial sanctions including a ban on public financing for trade with or investment in Belarus, restrictions on securities/loans/ deposits, a prohibition on transactions with the National Bank of the Republic of Belarus, and exclusion of listed Belarusian banks from SWIFT. The ordinance entered into force on the day it was adopted.

On 15 March 2022 the Council of the European Union adopted Regulation (EU) 2022/428, amending Regulation (EU) No 833/2014 (the fourth package of measures against Russia). It bans imports, purchase and transport of the iron and steel products listed in a new Annex XVII that originate in or are exported from Russia, bans the sale or export of Annex XVIII luxury goods to Russia (above EUR 300 per item unless otherwise specified), and prohibits transactions with the Russian state-controlled entities listed in Annex XIX. The Regulation entered into force on the day after its publication in the Official Journal (OJ L 87 I, 15.3.2022), i.e. 16 March 2022.

Regulations Amending the Special Economic Measures (Belarus) Regulations, SOR/2022-49, were registered and came into force on 8 March 2022. They add 19 individuals and 25 entities to Schedule 1 and widen the listing criteria to cover persons supporting the violation of Ukraine's sovereignty or territorial integrity. Listed entities named in the regulatory impact statement include the potash producer Belaruskali OAO and the Belarusian Potash Company, the Naftan Oil Refinery and Belneftkhim, and Absolutbank, Belinvestbank, Belbizneslizing and Bank Dabrabyt. Listing brings asset freezes and dealing prohibitions for persons in Canada.

On 4 March 2022 Switzerland's Federal Council adopted a total revision of the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), taking effect the same day at 18:00, to fully implement the EU's sanctions packages of 23 and 25 February 2022. The revision bans export of all dual-use goods to Russia regardless of end use or end user, bans export of goods that could contribute to Russia's military or technological strengthening or its defence and security sector, and prohibits export of specified goods and services to the oil sector, as well as goods for aviation, space and oil-refining/gas-liquefaction use.

On 2 March 2022 the Council of the European Union adopted Regulation (EU) 2022/355, amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus. It bans importing, purchasing or transporting products originating in or exported from Belarus in wood (Annex X), cement (Annex XI), iron and steel (Annex XII) and rubber (Annex XIII), and extends restrictions to potassium chloride ("potash"), tobacco and mineral products, plus a ban on exporting dual-use goods, machinery (Annex XIV) and goods usable for Belarus's military or security development. The measure responds to Belarus's active facilitation of Russia's invasion of Ukraine. It entered into force the day after publication in the Official Journal (OJ L 67, 2 March 2022), i.e. 3 March 2022, with a wind-down period to 4 June 2022 for pre-existing contracts.

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.

On 28 February 2022 the Swiss Federal Council decided to adopt the EU sanctions packages of 23 and 25 February 2022. As part of this, the import, export and investment ban in place for Crimea and Sevastopol since 2014 was extended to the Ukrainian regions of Donetsk and Luhansk that are not under Ukrainian government control. The Federal Council instructed the EAER to amend the existing ordinance in line with the EU measures.

SOR/2022-28, registered and in force on 24 February 2022, amends the Special Economic Measures (Ukraine) Regulations to prohibit persons in Canada and Canadians abroad from making investments involving property in the so-called Donetsk People's Republic and Luhansk People's Republic regions, from importing, purchasing or acquiring goods from them, and from exporting goods destined for them. It also bars related financial services, technical assistance and tourism-related services. The prohibitions are territorial and apply to goods generally; no product list is itemised.

On 24 February 2022 Japan's Foreign Minister announced sanctions following Russia's recognition of the "Donetsk People's Republic" and "Luhansk People's Republic". Japan suspended visa issuance to and froze assets in Japan of individuals of the two "Republics", prohibited imports from and exports to the two regions, and prohibited the issuance of and transactions in new Russian sovereign debt in primary and secondary markets. The relevant ministries were to proceed with the domestic procedures needed to implement them.

On 24 February 2022, hours after Russia's invasion of Ukraine began, the UK Foreign Secretary announced a full asset freeze on VTB, Russia's second-largest bank (£154bn in assets, 95,000 employees), alongside a freeze on all Russian bank assets in the UK and a ban on Russian companies raising finance on UK markets. The package designated more than 100 companies and individuals -- including five major defence firms (Rostec, Uralvagonzavod, Tactical Missile Corporation, United Aircraft Corporation, United Shipbuilding Corporation) and Putin-inner-circle figures such as Kirill Shamalov -- for asset freezes and travel bans. Aeroflot was banned from UK airspace and new export controls were imposed on electronics, telecommunications and aerospace goods to Russia.

The Autonomous Sanctions Amendment (Ukraine Regions) Regulations 2022 (F2022L00179) apply to the Ukrainian regions of Donetsk and Luhansk the autonomous sanctions measures already in place for Crimea and Sevastopol, commencing 28 March 2022. DFAT describes the measures as prohibiting trade in the transport, energy, telecommunications, and oil, gas and minerals sectors of those regions. Foreign Minister Marise Payne announced Australia's response on 24 February 2022, alongside listings of Russian individuals and banks.

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.

Between 22 and 28 February 2022 — coinciding with Russia's full-scale invasion of Ukraine — OFAC issued a Financial Services Sectoral Determination and four directives under Executive Order 14024 of April 15, 2021. Together they authorise designation of any person operating in Russia's financial sector, prohibit US persons from trading Russian sovereign debt, bar US banks from maintaining correspondent accounts for designated Russian financial institutions (Sberbank, Alfa-Bank and others), prohibit new investment in certain Russia-related entities, and block all transactions involving the Central Bank of the Russian Federation, the National Wealth Fund, and the Ministry of Finance — effectively freezing approximately USD 640 billion in Russian sovereign reserves held in Western financial systems. The package was formally published in the Federal Register on 31 May 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 amended the Weapons of Mass Destruction Proliferators Sanctions Regulations (31 CFR Part 544), implementing Executive Order 13382 (28 June 2005, blocking property of WMD proliferators and their supporters). The rule revised existing General License Section 544.507 by removing the requirement that all payment receipts for legal services must be specifically licensed, and added a new General License Section 544.508 authorising payments for legal services from funds originating outside the United States under defined conditions. The amendment aligns Part 544's legal-services framework with the broader cross-program approach OFAC was standardising across sanctions programmes during this period.

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.

The Treasury Department's Office of Foreign Assets Control (OFAC) amended and reissued the Transnational Criminal Organizations Sanctions Regulations (31 CFR Part 590) in their entirety to further implement Executive Order 13581 (July 24, 2011, "Blocking Property of Transnational Criminal Organizations") and Executive Order 13863 (March 15, 2019, "Taking Additional Steps to Address the National Emergency with Respect to Significant Transnational Criminal Organizations"). The reissuance replaces the abbreviated placeholder regulations published in 2012 with comprehensive text including additional interpretive guidance, definitions, general licenses, and other regulatory provisions to guide the public on compliance with OFAC's TCO sanctions programs.