Industrial Policy & Trade Monitor· 2670 actions· ✨ 89 recent

Signed by President Javier Milei and the entire cabinet on 20 December 2023 and published in the Boletín Oficial extraordinario on 21 December 2023, Decreto de Necesidad y Urgencia 70/2023 declares a public emergency across economic, financial, fiscal, administrative, pension, tariff, sanitary, and social matters until 31 December 2025 (Article 1) and enacts 366 articles across 16 titles that fundamentally restructure Argentina's regulatory framework. The DNU repeals or amends dozens of statutes to deregulate foreign trade (repealing the Compre Nacional buy-preference law Ley 18.875 and the price-control framework Ley 27.345), opens privatisation of state enterprises (Aerolíneas Argentinas, ENARSA, Banco Nación, Correo Argentino, Trenes Argentinos), dismantles the Ley de Abastecimiento price-control regime, liberalises civil aviation cabotage to foreign carriers, deregulates hydrocarbons export and mining permitting, and replaces the severance-pay regime with a capitalisation-fund system. It is the foundational enabling framework for all subsequent Milei-administration deregulatory instruments filed on the IPTM register, including RIGI (Law 27.742), Decreto 38/2025, Decreto 449/2025, and Decreto 563/2025.

The Bureau of Industry and Security (BIS) added 42 entities under 44 entries to the Entity List, effective December 7, 2023. The majority — 28 entities in Russia — are sanctioned for procuring or contracting on behalf of Russia's defense sector, including avionics, military-grade drones, and military electronics. Fourteen additional entities across Armenia, Belarus, Belgium, Cyprus, Germany, Kazakhstan, the Netherlands, China, and the UAE were added for operating diversion and transshipment networks that supply U.S.-origin items to Russian military end-users. All listed entities face a license requirement for all EAR-controlled items with a presumption of denial.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) issued a determination pursuant to Section 1(a)(i) of Executive Order 14014 identifying the jet fuel sector of the Burmese economy as a sanctions-eligible sector. The determination means that foreign persons who operate in Burma's jet fuel sector — including activities related to importation, exportation, reexportation, sale, supply, or transport of jet fuel in or involving Burma — may be designated and sanctioned by OFAC. Issued on the OFAC website on August 23, 2023 and formally published in the Federal Register on September 25, 2023 (FR Doc 2023-20713), the action was accompanied by concurrent SDN designations targeting key figures in the SAC junta's jet-fuel supply network.

BIS issued a correcting amendment to the EAR Entity List to add China Aviation Development Harbin Bearing Co., Ltd. — an AVIC subsidiary and specialist precision-bearing manufacturer — that was included in the preamble of the June 14, 2023 final rule (88 FR 38739) but inadvertently omitted from the regulatory text. The entity was designated for acquiring and attempting to acquire US-origin items in support of China's military modernization, including hypersonic weapons development, air-to-air missiles, and weapon lifecycle management using Western software. All EAR-subject items require a licence with a presumption of denial; retroactive effective date of June 16, 2023.

BIS published a final rule adding 43 entities under 50 entries to the EAR Entity List and removing one entity (Fiber Optic Solutions, Latvia), effective June 12, 2023. The additions span ten countries — China (31 entities), UAE (5), Pakistan (4), South Africa (3), UK (2), and one each in Kenya, Laos, Malaysia, Singapore, and Thailand — targeting four principal threat clusters: China's military modernization and hypersonic-weapons supply chain, an international network of flight-training academies (TFASA and affiliates) providing Western pilot training to Chinese military personnel, Pakistan-linked procurement for unsafeguarded ballistic-missile programs, and UAE/South Africa-based dual-use diversion networks. All listed entities require a BIS licence, with most subject to a presumption of denial.

The Bureau of Industry and Security (BIS) added eleven entities across Burma, China, Nicaragua, and Russia to the Entity List, effective March 28, 2023, under a human rights foreign policy rationale. Three Burmese trading companies and two Russian aviation-parts suppliers were designated for selling, procuring, and servicing military equipment enabling the Burmese military regime's attacks on civilians; five Xinjiang-based electronics manufacturers were added for activities contrary to U.S. foreign policy interests; and the Nicaraguan National Police was designated for serious human rights abuses. The rule simultaneously codified in the EAR that protection of human rights worldwide is an explicit basis for Entity List designations — a precedent-setting regulatory amendment extending the existing national-security and foreign-policy framework.

The Bureau of Industry and Security (BIS) added 76 Russian entities to the Entity List effective February 24, 2023, spanning three rationale categories: (1) biometric surveillance technology enabling Russian filtration operations in occupied Ukraine; (2) illicit acquisition of U.S.-origin controlled items; and (3) the Russian military-industrial complex encompassing missiles, aviation, shipbuilding, semiconductors, telecom, and defense electronics. All 76 entities are subject to a license requirement for all EAR-subject items with a presumption of denial; 66 entities receive footnote-3 designation as Russian military end-users, subjecting them to the Russia/Belarus Military End-User Foreign Direct Product Rule under §734.9(g). Four existing Entity List entries were simultaneously revised with additional aliases and tightened to a policy of denial. Notable designations include KAMAZ, the Skolkovo Foundation, Skoltech, Ilyushin Aviation Complex, and the State Missile Center Named After Akademika V.P. Makeyev.

The Bureau of Industry and Security expanded EAR sanctions against Russia and Belarus effective 24 February 2023, adding 322 HTS-6 industrial items to Supplement No. 4 to Part 746 (oil-and-gas equipment, flat-rolled steel, pumps, turbines, marine and aviation engines) and 276 luxury goods to Supplement No. 5. Supplement No. 6 was amended to add biological and chemical-synthesis equipment including bioreactors, peptide synthesizers, and nucleotide reagents, targeting Russia's biodefence and dual-use procurement pathway. The rule also migrated Supplement No. 2 from Schedule B to HTS-6 identifiers to align with allied partner frameworks, added Taiwan to the list of countries excluded from licence requirements, and extended Section 744.7 end-use restrictions to cover in-country transfers inside Russia and Belarus.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding seven Iranian entities to the Entity List effective 31 January 2023, for contributing to Russia's military and defense industrial base through the production and transfer of Iranian unmanned aerial vehicles (UAVs) used by Russia in Ukraine. The entities — including Shahed Aviation Industries, Qods Aviation Industry, and arms of the Islamic Revolutionary Guard Corps — are subject to a license requirement with a presumption of denial for all EAR-jurisdiction items. The rule applies the Russia/Belarus Military End User Foreign Direct Product (FDP) rule to all seven entities, extending its reach to foreign-produced items destined for or routed through these Iranian UAV producers.