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

On 16 December 2024 the Council of the European Union adopted Council Regulation (EU) 2024/3192 amending Regulation (EU) 833/2014, the 15th package of restrictive measures against Russia. The package adds 84 asset-freeze listings (54 individuals and 30 entities) under Regulation 269/2014 — for the first time including fully-fledged designations of seven Chinese individuals and entities supplying drone components, machine tools, and dual-use goods to the Russian military-industrial complex. It expands the EU shadow-fleet vessel- ban list by 52 tankers (total 79), activates the standalone EU hybrid- threats sanctions regime with its first 16-individual / 3-entity designations, extends the wind-down derogation for divestment from Russian subsidiaries to 31 December 2025, and reinforces anti- circumvention contractual clauses on EU exporters of dual-use goods.

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 11 October 2024, the Secretary of the Treasury — acting in consultation with the Secretary of State and pursuant to section 1(a)(i) of Executive Order 13902 — determined that the petroleum and petrochemical sectors of the Iranian economy are sectors of strategic concern, exposing non-US persons that operate in or knowingly facilitate significant transactions with those sectors to secondary sanctions and SDN-listing risk. The determination was issued in response to Iran's 1 October 2024 ballistic- missile attack on Israeli targets and was formally published in the Federal Register on 19 November 2024 (FR Doc 2024-26800). Concurrent with the determination, OFAC designated an international network — including Sepehr Energy Jahan Nama Pars — that had shipped millions of barrels of Iranian crude on behalf of Iran's Armed Forces General Staff to the People's Republic of China.

FinCEN issued a final order, published in the Federal Register on 11 October 2024 (signed 26 September 2024), prohibiting US covered financial institutions from engaging in transmittals of funds to or from PM2BTC, a virtual-currency exchange operating outside the United States and identified as a primary money-laundering concern in connection with Russian illicit finance. The order is the first use of FinCEN's special- measure authority under Section 9714(a) of the Combating Russian Money Laundering Act, as amended by the FY 2022 NDAA (codified at 31 U.S.C. 5323). The action was coordinated with same-day OFAC SDN designations of related entities (Cryptex) and individuals (Sergey Sergeevich Ivanov of Taleon Holdings).

The US Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register reporting instructions implementing Section 104(a) of the Rebuilding Economic Prosperity and Opportunity (REPO) for Ukrainians Act (P.L. 118-50, Division F, enacted April 24, 2024). All US financial institutions at which Russian sovereign assets are located — or that know or should know of such assets, including in correspondent or payable-through accounts — must report those holdings to OFAC using Form TD-F 93.09. Initial reports were due by August 2, 2024, with rolling reports required within 10 days of detecting newly identified Russian sovereign assets. The notice is the predicate step for any future US seizure or transfer of frozen Russian central bank, National Wealth Fund, or Russian Ministry of Finance assets to benefit Ukraine.

President Lukashenko signed Decree No. 278 on 10 July 2024, extending the prohibitive import customs duty regime established under Decree No. 16 (12 January 2024) through 30 June 2025, preventing its lapse at year-end 2024. The decree also expands the commodity list subject to elevated import duty rates. The measure explicitly frames the duties as retaliatory, targeting goods originating from states designated as "unfriendly" to Belarus — principally EU member states, the US, UK, Canada, Japan, Australia, New Zealand, Switzerland, Norway, Iceland, and other sanctioning jurisdictions. Co-ordinated with Russia's EAEU parallel-import framework (Resolution No. 506), the regime affects the cost arithmetic for sanctioned-goods routing through EAEU customs-union channels and signals continued institutionalisation of Belarus's counter-sanctions architecture.

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 24 June 2024 the Council of the European Union adopted Council Regulation (EU) 2024/1745, the 14th package of restrictive measures against Russia, amending Regulation (EU) 833/2014. The package introduces the EU's first targeted measures against Russian LNG (a ban on EU-port transhipment to third countries after a 9-month transition, and a prohibition on EU investment and goods/services exports to Russian LNG projects under construction such as Arctic LNG 2 and Murmansk LNG), bans EU entities outside Russia from using the SPFS Russian financial-messaging system, designates 27 named "shadow-fleet" tankers under a new vessel-specific port-access ban, and imposes a "best-efforts" obligation on EU parents to ensure non-EU subsidiaries do not engage in sanctions circumvention. It adds 116 new listings (69 individuals, 47 entities), including third-country circumvention enablers, to the asset-freeze and travel-ban regime.

OFAC final rule (FR Doc 2024-11618, 89 FR 46518) amending the Cuban Assets Control Regulations at 31 CFR Part 515 to further implement the May 2022 Biden administration policy of expanded support for the Cuban people. The rule reinstates the "U-turn" general license (authorizing US banks to process funds transfers that originate and terminate outside the US, neither originator nor beneficiary a US person); replaces "self-employed individual" with the broader "independent private sector entrepreneur" (covering Cuban private businesses up to 100 employees, including private cooperatives); authorizes Cuban nationals in the private sector and located in Cuba to open and operate accounts at US financial institutions (including via online/mobile banking); and expands authorizations for internet-based services to support Cuban civil society and private-sector entrepreneurs. Effective 29 May 2024.

Presidential Decree No. 442 of 23 May 2024 establishes a special judicial-administrative procedure by which the Russian Federation or the Central Bank of the Russian Federation can claim, before a Russian court, that an "unjustified deprivation" of Russian sovereign property has been effected by a state body or judicial authority of the United States — and, on a court finding to that effect, receive equivalent-value US-affiliated property located in Russia (real assets, securities issued by Russian companies, cash held in Russian bank accounts, and other property rights) by way of compensation. The mechanism is an explicit reciprocal counter-instrument to the US REPO for Ukrainians Act (Title II of H.R.815, signed 24 April 2024) authorising US executive confiscation of immobilised Russian sovereign assets in US jurisdiction. The decree is structurally extensible: by separate presidential decision, the same procedure may be applied to any other state Russia designates as "unfriendly". Implementing procedural acts and amendments to Russian legislation were required to be adopted by 23 September 2024.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) issued a final rule amending 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) to incorporate, with amendments, General License (GL) D-2 — originally issued on OFAC's website on September 23, 2022 — which authorizes the export, reexport, and provision of certain services, software, and hardware incident to communications over the internet to persons in Iran. The codification preserves the GL D-2 expansion (cloud-based services; third-country importation of hardware/software previously exported to Iran; ex-Iran installation, repair and replacement services; case-by-case licensing for internet-freedom activities) and updates the § 560.540 List of Services, Software, and Hardware Incident to Communications. Effective June 17, 2024, the List is amended to exclude laptops, tablets, and personal computing devices with an Adjusted Peak Performance (APP) exceeding 1 Weighted TeraFLOP (WT) — narrowing the consumer-electronics authorization to lower-performance devices and aligning the carve-out with broader BIS-style compute thresholds. The rule does not relax primary ITSR prohibitions; it codifies a humanitarian / internet-freedom exception while inserting a narrow high-performance-compute carve-out.

President Biden signed into law on 13 May 2024 the Prohibiting Russian Uranium Imports Act (Division H of the National Security Supplemental Appropriations Act, Public Law 118-50). The law bans imports to the United States of unirradiated low-enriched uranium (LEU) produced in Russia or by Russian state entities, effective immediately, with a waiver mechanism allowing the Department of Energy to grant case-by-case exceptions through 2027 where no alternative supply is available. The law also authorised up to $2.72B to support US uranium enrichment capacity via CENTRUS and allied enrichment partnerships.

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register "Directive 1 under Executive Order 14014, 'Prohibitions Related to Financial Services to or for the Benefit of Myanma Oil and Gas Enterprise.'" The Directive — originally issued on OFAC's website on 2023-10-31 with a 2023-12-15 effective date — determines that MOGE is a political subdivision, agency, or instrumentality of the Government of Burma and prohibits U.S. persons from providing, exporting, or reexporting, directly or indirectly, financial services to or for the benefit of MOGE. The Federal Register publication codifies notice of the Directive in the formal record of agency action; the underlying prohibition has been operative since December 2023.

OFAC issued two determinations under Executive Orders 14068 and 14071 banning the import into the United States of Russian-origin aluminum, copper, and nickel produced on or after April 13, 2024, and separately prohibiting the provision of warranting/deliverable services for these metals on global exchanges (LME, CME) and their use to settle over-the-counter derivative contracts. Metal produced before the effective date is grandfathered. The action was coordinated with the United Kingdom, which imposed parallel exchange-listing prohibitions the same day, following G7 statements on reducing Russia's metals revenue.

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.

Canada made SOR/2024-32, Regulations Amending the Special Economic Measures (Russia) Regulations, registered and effective 2024-02-21 on the second anniversary of Russia's invasion of Ukraine. The regulations add 163 persons to Schedule 1 — 10 individuals and 153 entities, predominantly Russian organizations tied to military-industrial production, logistics, insurance and oil-sector support — triggering Canadian dealing/asset bans. A parallel amendment to Schedule 7 adds five new goods categories under the Harmonized System (explosives and pyrotechnics; data-processing units and components; ball and roller bearings; semiconductor manufacturing equipment; optical and navigational instruments), banning their export to Russia or Russian persons.

OFAC amended § 510.512 of the North Korea Sanctions Regulations (31 CFR Part 510) to broaden the scope of authorized humanitarian activities for NGOs operating in North Korea, including permitting transactions with certain Government of North Korea entities where necessary to deliver authorized services. Three new general licenses were added: one for exports and re-exports of items licensed by the Commerce Department; one for agricultural commodities, medicine, and medical devices; and one for journalistic activities in North Korea. NGOs relying on the authorization must notify the State Department at least 30 days before commencing activity.

On 31 January 2024 Switzerland's Federal Council decided to align with the EU's 12th sanctions package (adopted 18 December 2023) by amending the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), entering into force the same day at 18:00. The update extends Switzerland's Russia-sanctions perimeter to match the EU's additions — including the Russian diamond, steel and other import-revenue restrictions — and adds a new financial-sector prohibition barring Russian nationals and Russia-resident individuals from controlling Swiss crypto-asset service providers, aimed at closing sanctions-circumvention and enforcement gaps.