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Structured register of government actions in the geoeconomic space — export controls, tariffs, sanctions, FDI screening, subsidies, industrial-policy laws — cross-referenced into the country, minerals, and ETF surface. Charter: docs/IPTM_CHARTER.md.
Severity 1-5 is the qualitative impact rating (1=minor, 5=structural). The bilateral-trade-grounded quant scorer is the next IPTM milestone. RBI (Register Breadth Index) is a complementary structural-breadth indicator from scripts/py/iptm/breadth.py; divergence between RBI and severity is itself informative (high-sev / low-RBI = strategic chokepoint; low-sev / high-RBI = broad but shallow). Every action has at least one primary source URL. Verify-or-don't-file. See also themes, timeline, graph, sankey, map, country exposure, sector exposure, material exposure (+ graph), weekly briefs, portfolio scan, escalation monitor, trans-shipment hubs. Internal triage tools (RSS-poller candidate feed, source-feed health) live under /admin/candidates + /admin/sources. Subscribe via Atom feed (accepts ?country=CN, ?material=lithium, ?issuer=BIS, ?type=export_control, ?etf=SOXX, ?company=NVDA, ?minSeverity=4, ?year=2026, ?q=…) or pull /api/iptm/actions.
The US Department of Commerce issued a preliminary affirmative determination (case A-570-228) that tin mill products from China are being sold in the US at less than fair value, finding a China-wide dumping margin of 136.52% based on adverse facts available (no Chinese producer/exporter responded to the investigation), adjusted to a 130.17% cash deposit rate after offsetting the parallel countervailing-duty determination. Commerce also made a preliminary affirmative finding of critical circumstances, extending provisional measures and cash-deposit collection retroactively. The investigation was petitioned by United States Steel Corporation and the United Steelworkers union; final determinations are scheduled for around 1 December 2026.
The US Department of Commerce issued a preliminary affirmative countervailing duty determination (case C-570-229) finding that producers/exporters of tin mill products from China received countervailable subsidies at a rate of 66.61% ad valorem, applied both to the individually-examined respondents (Shougang Holding Trade (Hong Kong) Ltd. and Shougang Jingtang United Iron & Steel Co. Ltd.) and to the all-others rate, based on facts available with adverse inferences after non-cooperation. Commerce also made a preliminary affirmative finding of critical circumstances, and directed CBP to suspend liquidation and collect cash deposits on entries from the date of publication. The final CVD determination is aligned to issue alongside the companion antidumping determination, currently scheduled no later than 2026-11-30.
On 9 September 2026 President Trump signed five proclamations under Section 338 of the Tariff Act of 1930 responding to Canada's 8 September 2026 retaliatory tariffs on roughly $20bn of US exports (steel, dairy, agricultural equipment). The proclamations impose outright import bans on certain Canadian alcoholic-beverage and dairy products that had been subject to the 50% Section 338 duties imposed 22 August 2026 (following Canada's continued discrimination against US alcohol and dairy commerce), and separately exclude certain Canadian motor-vehicle-sector products from importation for the same reason. The proclamations also modify the product scope of the July 20, 2026 Section 338 tariff actions, removing items such as rock salt and cement and adding others, including all-terrain vehicles and additional dairy products. The import bans take effect 29 September 2026; the product-list modifications take effect 15 September 2026. The duties/bans apply regardless of USMCA origin and stack on top of Section 232 tariffs.
China's Ministry of Commerce (MOFCOM) issued a preliminary anti-dumping ruling on imports of dichlorosilane (DCS, SiH2Cl2, HS 28539090) originating from Japan, finding dumping and material injury to the domestic DCS industry. Effective September 8, 2026, importers must post cash deposits with Chinese customs at company-specific provisional rates: 99.2% for Shin-Etsu Chemical Co., Ltd. and all other Japanese producers, and 80.8% for Denal Silane Co., Ltd. DCS is a precursor gas used in chip-fab thin-film deposition (epitaxial, silicon-carbide, silicon-nitride, oxide and polysilicon films) for logic, memory and analog semiconductors. The investigation was initiated January 7, 2026 (MOFCOM Announcement 2026 No. 2); a final determination is pending.
China's Ministry of Commerce announced that drones, key drone components, and related technologies already listed on China's Dual-Use Items Export Control List will be subject to strict case-by-case review when exported to the United States, and will no longer be eligible for licensing-facilitation measures. The measure does not add new items to the control list or ban exports outright — it tightens the review standard and removes expedited-licensing treatment for existing listed drone items. MOFCOM said the move is a countermeasure responding to recent US actions, including the FCC's ban on imports of Chinese drones and DHS's addition of 43 Chinese companies to the Uyghur Forced Labor Prevention Act entity list.
On 29 July 2026 Allied Gold Corporation (TSX/NYSE: AAUC) and Zijin Gold International Company Ltd. terminated their previously announced C$5.5B (~US$3.9-4B) arrangement agreement, under which Zijin Gold would have acquired 100% of Allied Gold, after concluding the deal's closing conditions would not be satisfied by the 29 July 2026 outside date. Trade press (ION Analytics/Dealreporter, Investing News Network, Ecofin Agency) reports the transaction stalled because China's National Development and Reform Commission (NDRC) required in-depth review over two concerns: the premium Zijin was paying relative to Allied's market valuation, and geopolitical-risk concentration from Allied's exposure to Mali, which supplies roughly half of Allied's gold output (via the Sadiola mine). In place of the full takeover, Zijin Gold agreed same-day to a non-brokered private placement subscribing for ~12.8 million Allied common shares at C$32.55/share (~US$295M gross proceeds), taking a 9.2% stake expected to close on or about 10 August 2026. This is the first Chinese outbound mining M&A the register has logged since 2025-04-23, following a roughly 16-month gap, and marks an outbound-investment-screening precedent constraining a Chinese SOE-adjacent acquirer's exposure to Sahel political risk.
China's Ministry of Commerce issued Announcement No. 30 of 2026 on July 24, 2026, adding 14 EU-based entities to the Export Control Management List under the Export Control Law and Dual-Use Items Export Control Regulations. The listing bars Chinese exporters from supplying dual-use items to the named entities, bars any overseas party from transferring or providing China-origin dual-use items to them, and orders ongoing related transactions to stop immediately; exporters may apply to MOFCOM for case-by-case exemption. It is the first MOFCOM entity-list action ever to target EU-domiciled entities and the first ever to name a university (Wrocław University of Science and Technology). The 14 entities span Germany (Rheinmetall AG, Sindlhauser Materials GmbH, Antraco Chemie-Handelsgesellschaft mbH), Italy (Lafert S.p.A., Garnet S.r.l.), France (InPACT S.A., III-V LAB, Cavok UAS), Poland (Vigo Photonics S.A., Politechnika Wrocławska), the Netherlands (IHC Merwede Holding B.V.), Czechia (TATRA TRUCKS a.s.), Bulgaria (Opticoelectron Group) and Lithuania (Ekspla UAB) — defence, drone, photonics, laser, semiconductor and maritime-engineering firms and research institutes. The action came roughly 24 hours after the EU's 21st Russia sanctions package (adopted July 23, 2026) added Chinese and Hong Kong dual-use-trading entities to its own restricted list, and is widely read as a reciprocal countermeasure.
On 29 June 2026 China's Ministry of Commerce issued Announcement No. 27 [2026], adding 20 Japanese entities to the dual-use-item export-control Control List (受控名单) under the Dual-Use Export Control Regulations. The designated entities include four defense research institutes (National Institute for Defense Studies plus ground-, naval- and air-systems research bodies) and 16 companies, primarily Mitsubishi Electric and Mitsubishi Heavy Industries subsidiaries. The Control List designation imposes an absolute prohibition on exporting PRC-origin dual-use items — including rare earths and gallium/germanium/antimony-class strategic minerals — to the listed parties, and bars any third-country transfer of Chinese-origin dual-use items to them; ongoing supply activity must cease immediately, with exceptions only via special MOFCOM application. MOFCOM stated the action targets entities "involved in enhancing Japan's military capabilities."
China's Ministry of Commerce issued Announcement No. 23 of 2026 on June 22, 2026, adding 10 US entities to the Export Control Management List under the Export Control Law and Dual-Use Items Export Control Regulations. The listing prohibits Chinese exporters from supplying dual-use items to these entities and bars any global party from transferring China-origin dual-use goods to them; ongoing transactions are suspended pending MOFCOM approval. The 10 entities include the two largest non-Chinese rare earth producers — MP Materials Corp. (Mountain Pass, CA) and USA Rare Earth Inc. (Round Top, TX) — as well as eight US defence firms (Aveox, Red Cat Holdings, Teal Drones, IMSAR, Jaia Robotics, Ball Aerospace, Oshkosh Defense, L3Harris Maritime). MOFCOM explicitly framed the action as retaliation for the US DoD's June 8, 2026 update to the Section 1260H Chinese Military Companies list, which added ~80 Chinese parent firms and 188 affiliates.
On June 17, 2026, BIS announced a $36,184,680 civil penalty settlement with Robert Bosch GmbH (Stuttgart, Germany) — the largest-ever BIS enforcement penalty against a non-US company for Foreign Direct Product Rule (FDPR) violations. Between September 16, 2020 and September 26, 2024, Bosch exported approximately $72.4 million in MEMS sensor products and automotive software from abroad to Huawei Technologies and its Entity List affiliates without the required BIS license. Bosch filed a Voluntary Self-Disclosure and cooperated throughout; the DOJ issued the first-ever NSD declination under its newly established Corporate Enforcement Policy, declining criminal prosecution entirely.
On 4 June 2026 USTR published a formal Notice of Determination in the Federal Register (doc 2026-11158, docket USTR-2025-0043) concluding that Brazil's acts, policies, and practices in six areas — digital trade and electronic payment services, unfair preferential tariffs, anti-corruption enforcement, IP protection, ethanol market access, and illegal deforestation — are unreasonable and burden US commerce. Simultaneously, USTR proposed a 25% ad valorem tariff on all Brazilian-origin goods, subject to ~1,600 HTS subheading exclusions including approximately 430 civil-aircraft lines. A public hearing is scheduled for 6 July 2026 and USTR faces a statutory deadline of 15 July 2026 to finalise any responsive action; the tariff has not yet taken effect.
President Trump signed an Executive Order on June 3, 2026 restructuring the entire US customs-entry compliance architecture for global importers. Key provisions impose heightened bonding minimums and domestic-asset requirements for foreign importers of record (IORs), require CAATSA-compliance and supply-chain-disclosure certifications, restrict foreign IORs to formal entry only (creating a de facto US-IOR monopoly on informal entry), establish a "good standing" requirement for IOR eligibility, and sharply curtail CBP's mitigation authority while setting enhanced penalty floors. DHS/CBP is directed to implement penalty-floor, export-documentation, and disposal provisions within 90 days (~September 2026) and the IOR structural reforms within 180 days (~November 2026). The EO is structurally distinct from tariff-rate instruments (Section 232 Proclamations 11021/11032), trade-remedy channels (USTR Section 301), statutory forced-labor enforcement (UFLPA), and targeted-sanctions channels (BIS/OFAC) — it reshapes the foundational compliance architecture through which all goods enter the US market.
On June 3, 2026, USTR formally initiated a Section 301 investigation (FR Doc. 2026-11043) into Vietnam's acts, policies, and practices relating to intellectual property protection and enforcement. This is the first Vietnam-specific Section 301 investigation carrying tariff-imposition authority — distinct from the Special 301 process (Section 182, which designates but cannot impose tariffs) and from the simultaneous June 2, 2026 forced-labor Section 301 (60 economies) and March 11, 2026 overcapacity Section 301. USTR proposes additional duties of 10–12.5% on Vietnamese goods if the investigation confirms actionable IP failures. The public comment period closes July 6, 2026.
On 19 May 2026, Treasurer Jim Chalmers announced a further overhaul of Australia's foreign investment framework under the Foreign Acquisitions and Takeovers Act 1975. The package introduces a performance target of processing all low-risk applications within 30 days from 1 January 2027, expands the exemption-certificate regime for repeat low-risk investors, and eliminates approval requirements for certain low-risk transaction types. Countervailing measures tighten the framework: enhanced compliance and enforcement powers are added for avoidance and non-compliance, and screening requirements are explicitly increased for sensitive sectors including critical minerals, critical infrastructure, critical technology, sensitive data, and defence-site-proximate assets.
The U.S. Treasury's Office of Foreign Assets Control (OFAC) announced on 18 May 2026 that Adani Enterprises Limited (AEL), a flagship publicly traded entity of India's Adani Group (NSE: ADANIENT), agreed to pay $275,000,000 to settle apparent civil liability for violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 CFR Part 560) arising from AEL's purchases of liquefied petroleum gas (LPG) shipments through a Dubai-based commodity trader between November 2023 and June 2025, where red flags should have placed AEL on notice that the LPG originated from Iran. Approximately $192 million in payments for the Iranian-origin LPG shipments were processed through US financial institutions, providing the US nexus for OFAC jurisdiction. OFAC determined the apparent violations were EGREGIOUS and not voluntarily self-disclosed; AEL did not admit fault but committed to implementing enhanced compliance measures. The settlement is the largest OFAC enforcement action against an Indian corporate entity on record and was announced concurrently with parallel DOJ and SEC resolutions forming part of a broader US legal-relief package for the Adani Group.
Prime Minister Phạm Minh Chính issued Directive 38/CĐ-TTg on 5 May 2026, mobilising a cross-ministerial enforcement campaign against intellectual property infringement running 7–30 May 2026 with a 31 May reporting deadline. The directive explicitly responds to the USTR 2026 Special 301 designation of Vietnam as a Priority Foreign Country — the first such designation in eleven years — which triggers a statutory 30-day window for USTR to decide whether to open a Section 301 investigation. Ministries of Public Security, Industry and Trade (Market Surveillance), Information and Communications, and Culture are mobilised for coordinated raids targeting counterfeit-goods exporters, pirated-content platforms, and software-copyright violators, with the Prime Minister signalling enforcement will be permanent rather than a one-off campaign.
On 2 May 2026, MOFCOM issued Announcement No. 21 of 2026 — the first concrete prohibition order ever issued under China's 2021 "Rules on Counteracting Unjustified Extra-territorial Application of Foreign Legislation and Other Measures" (Blocking Rules) and the Anti-Foreign Sanctions Law (AFSL). The order prohibits any Chinese organisation, individual, or foreign party operating in China from recognising, enforcing, or complying with US sanctions imposed under Executive Orders 13902 and 13846 against five Chinese independent ("teapot") refineries — Hengli Petrochemical (Dalian) Refining Co., Ltd., Shandong Shouguang Luqing Petrochemical Co., Ltd., Shandong Jincheng Petrochemical Group Co., Ltd., Hebei Xinhai Chemical Group Co., Ltd., and Shandong Shengxing Chemical Co., Ltd. — all designated by OFAC for purchasing Iranian crude. The announcement is the first operational test of the framework built up across the AFSL (2021), the AFSL Implementation Regulations (Order 803, March 2025), and State Council Order 835 on Countering Foreign Unlawful Extraterritorial Jurisdiction (April 2026), and creates a direct compliance conflict for banks, insurers, traders, and shipping companies operating in or with China that had been winding down their exposure to the listed refineries.
On May 1, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated China-based independent ("teapot") refinery Hengli Petrochemical (Dalian) Refinery Co., Ltd. — described as China's second-largest teapot — together with approximately 40 shipping firms and vessels operating as part of Iran's shadow fleet. OFAC sanctioned 19 shadow-fleet vessels (crude, LPG, and petrochemical tankers) as blocked property of designated owners or managers. The action was taken under Executive Order 13902 (Iran petroleum and petrochemical sectors) in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. Treasury press release SB0472. Concurrent with the designations, OFAC issued Iran-related General License W authorising the wind-down of transactions involving the persons newly blocked on May 1, 2026, and published a structurally novel Iran-related Alert, "Sanctions Risks of Iranian Demands for Strait of Hormuz Passage." The Alert states that payments to the Government of Iran or the IRGC — directly or indirectly — for safe passage through the Strait of Hormuz are not authorised for US persons (including US financial institutions) or US-owned/-controlled foreign entities. OFAC also issued new FAQ 1250 to accompany the Alert and GL W. The wave is one of the largest single-day Iran enforcement actions of the Trump 2.0 administration. Treasury characterises it as part of a campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The Strait of Hormuz Alert is the operational US response to Iranian regulatory threats against the ~20% of global oil and ~25% of global LNG transiting Hormuz, putting tanker owners, P&I clubs, flag states, and oil-buyer compliance teams on direct notice.
On April 30, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) added former Democratic Republic of the Congo President Joseph Kabange Kabila to the Specially Designated Nationals (SDN) List pursuant to Executive Order 13413, as amended by Executive Order 13671 (the DRC sanctions program), for having materially assisted, sponsored, or provided financial, material, or technological support to the March 23 Movement (M23) and its political-military coalition the Congo River Alliance (Alliance Fleuve Congo, AFC). Treasury press release SB0480 ("Treasury Sanctions Former Democratic Republic of the Congo President for Ties to Armed Conflict") frames the designation as enforcement of the Washington-brokered DRC-Rwanda framework: M23 controls a substantial share of mineral-rich eastern DRC (cobalt, coltan, tin, tungsten, gold) and AFC's renewed rebellion has fuelled a mass-displacement crisis. The notice was published in the Federal Register on May 5, 2026 (FR Doc. 2026-08672). The designation blocks all property and interests in property of Kabila subject to US jurisdiction and prohibits US-person dealings with him. It is a discrete enforcement step under the broader US-DRC Strategic Partnership Agreement (4 December 2025 — the "Washington Accords") and complements earlier 2026 designations of Rwanda Defence Force-linked actors. Treasury frames the action as signalling that political support to M23/AFC, not just direct military or commercial activity, will trigger blocking sanctions.
The Office of the United States Trade Representative released the 2026 Special 301 Report on 30 April 2026, designating Vietnam as a Priority Foreign Country (PFC) — the most severe category under Section 182 of the Trade Act of 1974 (19 U.S.C. § 2242). This is the first PFC designation since Ukraine held the status from 2013 through 2015, a gap of approximately 11 years. The PFC designation triggers a statutory 30-day window (expiring ~30 May 2026) within which USTR must decide whether to initiate a Section 301 investigation under 19 U.S.C. § 2412(b)(2)(A), which could lead to tariffs, withdrawal of trade benefits, or other Section 301 enforcement remedies against Vietnam. Separately, the EU was added to the Watch List for the first time, citing AI training-data, geographical-indications, and customs-enforcement concerns.
President Félix Tshisekedi mandated a 30-day audit at the 87th Council of Ministers (April 24, 2026) to track DRC mining export revenues from shipment through foreign-currency repatriation to government receipt, targeting copper and cobalt — the country's two dominant export minerals. The directive responds to a systemic gap between record 2025 export volumes (~3.4 Mt copper, ~220 kt cobalt) and proportional state revenue collection, and builds on a prior audit that identified ~$16.8 billion in underreported revenues between 2018 and 2023. Initial findings are due no later than June 15, 2026, and enforcement exposure is concentrated on the major vertically integrated operators — Glencore, CMOC, and Ivanhoe Mines.
On April 24, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) added 19 entities and 19 vessels to the Specially Designated Nationals (SDN) List under Executive Order 13902 (Iran petroleum and petrochemical sectors), in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. The action is the first OFAC designation of a Chinese independent ("teapot") refinery — Hengli Petrochemical (Dalian) Refinery Co., Ltd., described as one of Iran's largest single customers for crude oil and petroleum products, having purchased billions of US dollars' worth since at least 2023 from cargoes brokered by Sepehr Energy Jahan Nama Pars Company (the oil sales arm of Iran's Armed Forces General Staff, controlled by the Ministry of Defense / MODAFL). Co-designations span shipping firms and vessels registered in China, Hong Kong, Panama, Marshall Islands, Liberia, and Vietnam. Concurrent with the designations, OFAC issued Iran-related General License V authorising a 30-day wind-down (through May 24, 2026) of transactions involving Hengli Petrochemical (Dalian) Refinery Co., Ltd. and certain majority-owned entities. Treasury press release SB0472 ("Economic Fury Targets Global Network Fueling Iran's Oil Trade and Shadow Fleet") frames the action as part of the maximum-pressure campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The April 24 designations directly triggered the first-ever operational use of China's Blocking Rules (MOFCOM Announcement No. 21 of May 2, 2026) and preceded a second OFAC Iran wave on May 1, 2026 (General License W + Strait of Hormuz Sanctions Risk Alert).
On 21 April 2026 the European Commission issued a conditional clearance under the EU Foreign Subsidies Regulation (FSR, Regulation 2022/2560), requiring the exclusion of CRRC (China's largest rolling-stock manufacturer) from the Lisbon Metro Violet Line procurement — the first-ever FSR procurement remedy ordering a Chinese supplier exclusion from a specific EU public contract. The Commission found that CRRC received foreign subsidies enabling it to submit an unduly advantageous tender, and as a condition of clearance mandated CRRC's removal from the tender. CRRC was replaced by PESA (Polish rail manufacturer) as the selected bidder. Unlike the 2024 Bulgaria/CRRC case (FSP.100147) where CRRC voluntarily withdrew before a formal decision, the Lisbon case produced the first binding FSR exclusion remedy, establishing mandatory supplier-removal as an available enforcement outcome in EU public procurement.
On 16 April 2026 the Government of Burkina Faso published Decree No. 2026-0287/PF/PRIM/MEF/MEMC in the Journal Officiel du Burkina Faso, authorising SOPAMIB — the state's strategic mining-participation vehicle — to acquire an additional 25% stake in Kiaka SA, the operating entity of West African Resources' (ASX: WAF) Kiaka gold mine, for 70 billion CFA francs (~A$175M / USD $125M). The acquisition raises total state equity from the 15% mandatory free-carry established under the 2024 Mining Code (Loi N°016-2024) to 40%, leaving West African Resources with a 60% operating interest; WAF's Sanbrado and Toega operations are not referenced in the decree. West African Resources confirmed the decree via an ASX regulatory announcement on 21 April 2026, noting that net proceeds will be returned to shareholders as a special dividend and that WAF will work with SOPAMIB to finalise transaction terms by end-2026. This action is structurally distinct from the June 2025 SOPAMIB nationalisation of five Endeavour/Lilium assets (Wahgnion, Boungou, three exploration entities), which involved a full transfer; the Kiaka decree is a compulsory additional equity dilution at a specific operating mine, deepening the Burkinabè junta's resource-nationalism arc under President Capt. Ibrahim Traoré.
The European Commission approved Germany's €3.8 billion industrial electricity price relief scheme (Industriestrompreis, State Aid Case SA.120495) on 16 April 2026 under Section 5 of the Clean Industrial Deal State Aid Framework (CISAF), covering the period 1 January 2026 to 31 December 2028. The scheme compensates companies in 91 electricity- and trade-intensive sectors for electricity costs above a reference wholesale price floor, subject to a binding conditionality requiring reinvestment of at least 50% of aid in decarbonisation assets within 48 months. The Commission approved the German scheme as part of a coordinated three-Member-State decision also covering parallel Bulgarian and Slovenian electricity price relief schemes, with the combined package totalling approximately €4.22 billion. This is the largest individual CISAF disbursement approved to date, at 11.4× the scale of the parallel Bulgaria SA.120414 scheme (€334m), and establishes the Section-5 upper-bound precedent for EU energy-intensive-industry relief.
The European Commission approved Bulgaria's Electricity Price Relief Scheme (State Aid Case SA.120414) under the Clean Industrial Deal State Aid Framework (CISAF), authorising €334 million for energy-intensive industries over a three-year corridor from 1 July 2025 to 30 June 2028. Aid is delivered via a reduction on beneficiaries' monthly electricity bills through their suppliers, subject to a minimum price floor of €50/MWh. This is the first EU member-state scheme approved under the CISAF framework, establishing the precedential template for subsequent CISAF approvals across the EU industrial base.
Premier Li Qiang signed State Council Order No. 835 on 13 April 2026 promulgating the "Regulations of the People's Republic of China on Countering Foreign States' Unlawful Extraterritorial Jurisdiction" (20 articles), effective on the date of publication. The Regulations are the first State Council–level administrative regulation to operationalise the PRC's framework for identifying and countering foreign extraterritorial measures on a horizontal basis, complementing the 2021 Anti-Foreign Sanctions Law and the March 2025 AFSL implementation regulations. Article 5 establishes a State Council–led inter-agency coordination mechanism; Article 6 vests the State Council legal affairs department (the Ministry of Justice in practice) with authority to identify "improper" foreign extraterritorial measures and to grant exemptions; Article 8 authorises a new Malicious Entity List targeting foreign organisations and individuals that "promote or participate in implementing" such measures, with nine countermeasure categories spanning visa denial, asset freezing, trade restrictions and fines; Article 11 codifies an exemption-application channel under which Chinese persons facing conflicting legal demands may request approval to comply with foreign measures within a defined scope; Article 14 authorises a private right of action for harmed Chinese citizens and organisations to sue parties enforcing such measures; and Article 18 elevates enforcement beyond administrative penalties by referencing potential criminal liability.
The UK Finance Act 2026, which received Royal Assent on 18 March 2026, establishes the primary statutory framework for the United Kingdom Carbon Border Adjustment Mechanism (UK CBAM), granting HM Revenue & Customs the assessment, collection, and enforcement powers needed to apply a carbon-content levy on imports of aluminium, cement, fertilisers, hydrogen, and iron & steel from 1 January 2027. Two tranches of draft secondary legislation (the CBAM Regulations 2026 covering administration, rate calculation/carbon-price relief, emissions and verification, and transitory provisions) were published for technical consultation on 10 February 2026 (closing 24 March 2026) and again in Spring 2026 (closing 21 May 2026). The mechanism imposes a UK ETS-linked benchmark price on the embedded carbon of in-scope imports, with a credit for verified third-country carbon prices already paid, and — unlike the EU CBAM — has no transitional reporting phase and a narrower initial sectoral scope (no electricity).
On 11 March 2026 USTR Ambassador Jamieson Greer initiated parallel Section 301 investigations into the acts, policies, and practices of 16 economies — China, the European Union, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan, and India — relating to structural excess capacity and overproduction in manufacturing sectors. The Federal Register notice (FR doc 2026-05214; dockets USTR-2026-0067 and USTR-2026-0068) was published on 17 March 2026. Covered sectors include aluminum, automobiles, batteries, cement, chemicals, electronics, energy goods, glass, machine tools, machinery, paper, plastics, processed food and beverages, robotics, satellites, semiconductors, ships, solar modules, steel, and transportation equipment. Written comments were due by 15 April 2026; USTR held the public hearing beginning 5 May 2026. This is the most sweeping multi-economy Section 301 initiative since the 2018 China investigation and is structurally distinct from the China-only 2024-05-14 §301 tariff hikes and the 2025-07-15 Brazil §301 investigation.
The US Department of Commerce published its final affirmative determination of sales at less-than-fair-value in the antidumping investigation of animal feed-grade L-lysine (lysine) from China (case A-570-215) on 23 July 2026, following a preliminary determination published 6 March 2026 (91 FR 11030). Commerce found a China-wide weighted-average dumping margin of 139.83% (cash deposit rate 139.65% after subsidy-offset adjustment), based on adverse facts available after Commerce found Zhengzhou Longgu Trading Co., the sole company with a calculated margin, and the Eppen Group group of producers/exporters uncooperative and ineligible for a separate rate in the final determination. A group of separate-rate companies — including Anhui BBCA Biochemical, Heilongjiang Wanlirunda Biotechnology, and others exporting through trading intermediaries such as Agromate Sg, Ainore (Tianjin), and Aollen Biotech — received a 73.55% dumping margin (73.37% cash deposit rate). The order covers lysine regardless of form (HCl, sulfate, liquid) under HTSUS 2922.41.0090 and related subheadings. A companion countervailing-duty investigation (preliminary 22 January 2026, 91 FR 2745) was finalized the same day; suspension of liquidation runs from 6 March 2026, with a final AD order contingent on an ITC injury determination due within 45 days of the final LTFV finding.
At the PDAC Convention 2026 in Toronto, Canada's Minister of Energy and Natural Resources Tim Hodgson announced the Critical Minerals Sovereign Fund (CMSF), a CAD 2 billion vehicle to be operated by Natural Resources Canada that will deploy equity investments, debt, and offtake agreements into Canadian critical-minerals projects and companies. Initial focus covers six of Canada's 34 critical minerals — copper, nickel, lithium, graphite, cobalt, and rare earth elements — with capital expected to begin flowing in spring 2026. The CMSF is part of a broader CAD 3.6 bn PDAC-day announcement package that NRCan estimates will unlock CAD 12.1 bn in mining-project capital across 30+ partnerships, and is structurally modelled on Australia's Critical Minerals Strategic Reserve.
On 24 February 2026 China's Ministry of Commerce simultaneously issued Announcement No. 11 and Announcement No. 12 [2026], activating for the first time the Control List (受控名单) mechanism under Article 28 and the Watch List (关注名单) mechanism under Article 26 of the Dual-Use Export Control Regulations (effective 1 December 2024), designating 40 Japanese entities in total. The Control List (20 entities, led by Mitsubishi Heavy Industries Shipbuilding Co.) imposes an absolute prohibition on any person or entity worldwide supplying PRC-origin dual-use items to listed parties; the Watch List (20 entities, led by SUBARU Corporation) bars general licensing and requires exporters to file risk assessments and non-military-use commitments. MOFCOM framed both measures as a response to Japan's "remilitarization" trajectory, escalating well beyond the blanket enhanced- review framework established by Announcement No. 1 [2026] in January.
On 3 February 2026 the European Commission opened an in-depth Phase II investigation under the Foreign Subsidies Regulation (FSR) — the second FSR ex officio case and the first targeting the renewable-energy wind-OEM sector — into whether Xinjiang Goldwind Science & Technology Co., Ltd. and its EU affiliates received Chinese foreign subsidies (grants, preferential tax treatment, and state-bank preferential financing) that distort competition for wind-turbine supply and services in the EU internal market. The case (FS.100143) follows the April 2024 preliminary-review opening and subjects Goldwind to an 18-month Phase II investigation with potential redressive-measures decision. The action structurally extends the FSR enforcement perimeter from security equipment (Nuctech, FS.100068) into the green-transition energy-equipment supply chain.
On 30 January 2026, Justice Perram of the Federal Court of Australia ordered Indian Ocean International Shipping and Service Company Ltd and its sole director Ms Jing Tian to pay a combined AUD 14 million civil penalty (Indian Ocean AUD 10 million; Ms Tian AUD 4 million) for contravening a June 2024 Treasurer disposal order under the Foreign Acquisitions and Takeovers Act 1975 (Cth). The disposal order had directed Indian Ocean to divest its 613.5 million shares in Northern Minerals Limited (ASX: NTU) — operator of the Browns Range heavy-rare-earth dysprosium and terbium project in Western Australia — by September 2024 on national security grounds. Instead, Indian Ocean transferred its NTU shares to Ms Tian in August 2024, who briefly returned then re-received them before Ms Tian transferred all 100 of her Indian Ocean shares to Ms Ning Lyu and resigned as director. The court ruled these transfers constituted a breach of the disposal order. This is the first civil-penalty action brought by an Australian Treasurer under the Foreign Acquisitions and Takeovers Act since its introduction in 1975, and the first FIRB enforcement penalty outside the residential real estate sector.
South Korea's National Assembly passed the "Special Act on Strengthening and Supporting the Competitiveness of the Semiconductor Industry" (반도체산업 경쟁력 강화 및 지원에 관한 특별법) on 29 January 2026 by 199 votes in favour out of 206 members present, after roughly 18 months of inter-party deadlock. The act establishes (i) a Presidential Commission for Enhancing Semiconductor Competitiveness as the central inter-ministerial coordination body, (ii) a statutory five-year master plan with annual implementation plans, (iii) a dedicated semiconductor industry special account ("반도체산업 특별회계") to ring-fence funding for fabs, materials, parts and equipment, and packaging across the full memory + system-LSI + design + manufacturing supply chain, and (iv) authority to designate semiconductor clusters outside the greater Seoul area with relocation incentives. Promulgation by the Cabinet is expected shortly after passage; effectiveness contingent on enforcement-ordinance finalisation, expected Q3 2026. The KRW 2tn anchor envelope of the special account does not begin disbursing until 2027 because companion amendments to the National Finance Act were not enacted in time.
On 9 February 2026 the UK Office of Financial Sanctions Implementation (OFSI) published a comprehensively revised enforcement and monetary-penalties guidance following its July–October 2025 public consultation. The update introduces a Settlement Scheme (20% penalty discount for subjects who agree not to contest OFSI's findings within 30 business days), an Early Account Scheme (up to 20% discount for legal persons providing a timely senior-attested factual account), a revised voluntary-disclosure framework (maximum discount cut from 50% to 30% and renamed to cover both prompt self-reporting and full cooperation), a four-level case-assessment seriousness matrix (severity × conduct), and fixed monetary penalties of £5,000 and £10,000 for information, reporting, and licensing offences. A planned legislative amendment (requiring primary legislation) will subsequently double the statutory civil monetary-penalty cap from £1m / 50%-of-breach to £2m / 100%-of-breach; in the interim the Policing and Crime Act 2017 caps remain in force. The revised guidance is the foundational enforcement architecture for all UK financial-sanctions programs (Russia, Iran, DPRK, Syria, Belarus, Myanmar, and 10+ additional regimes).
The US Department of Commerce published its final affirmative countervailing-duty (CVD) determination on animal feed-grade L-lysine from China (case C-570-216) on 23 July 2026, the companion subsidy proceeding to the parallel antidumping case (A-570-215) finalized the same day. Commerce found Heilongjiang Wanlirunda Biotechnology Co., Ltd. and Shouguang Golden-land Industry & Trading Co., Ltd. received countervailable subsidies at 82.11%, while Inner Mongolia Eppen Biotech Co., Ltd. and all other Chinese producers/exporters were assigned a 48.21% subsidy rate. The preliminary CVD determination, published 22 January 2026, set the initial cash-deposit rates and suspension of liquidation; the final determination confirmed and aligned the case with the AD final determination for a joint ITC injury vote.
Peru's Decreto Legislativo N° 1695 (published El Peruano 20 January 2026) amends the Código Penal (Legislative Decree N° 635) to substantially escalate criminal penalties for illegal mining and illegal-origin mineral trafficking. Art 307-A (illegal mining) now carries 5–8 years imprisonment; Art 307-E (trafficking chemical precursors and machinery) and a new Art 307-F (trafficking illegal-origin mineral resources — covering transport, storage, export- loading, and commercialisation) each carry 6–9 years plus 100–600 días-multa. A new Art 307-G adds an inhabilitación penalty barring offenders from mining concessions and mineral commercialisation. The decree also amends Ley N° 30077 (Ley contra el Crimen Organizado) to formally classify illegal mining offences (Arts 307-A through 307-F) as organised crime, unlocking FECOR prosecutorial tools including controlled-delivery operations, FIU cooperation, money-laundering enhancements, and civil asset forfeiture.
On 19 January 2026 the Government of Vietnam issued Decree No. 29/2026/ND-CP, establishing the regulatory architecture for Vietnam's first domestic carbon trading exchange. The decree (6 chapters, 35 articles) governs registration, domestic coding, ownership transfer, custody, trading and settlement of greenhouse gas (GHG) emission quotas and eligible carbon credits. The Hanoi Stock Exchange (HNX) operates the trading platform and the Vietnam Securities Depository and Clearing Corporation (VSDC) handles registration, custody and settlement, with a pilot phase running through 31 December 2028 (no exchange-services fee) ahead of full commercialisation from 1 January 2029.
The US Department of Commerce issued affirmative preliminary countervailing duty (CVD) determinations on hardwood and decorative plywood from China, Indonesia, and Vietnam, finding countervailable government subsidies in all three countries. Preliminary subsidy rates are 81.34% for China, 2.40% to 128.66% for Indonesia (case-by-case, non-cooperating producer PT Mustika Buana Sejahtera at the top of the range), and 4.37% to 26.75% for Vietnam. Commerce published the determinations in the Federal Register on 22 January 2026, triggering CBP collection of cash deposits at these rates pending final determinations. A parallel antidumping (AD) investigation on the same product and countries runs on a separate track (see responds_to) with preliminary AD margins of 187.27% (China), up to 84.94% (Indonesia), and 196.14% (Vietnam) announced 25 February 2026 — AD and CVD duties stack cumulatively.
The US Department of Commerce issued a countervailing duty (CVD) order on steel concrete reinforcing bar (rebar) from Algeria, effective 6 July 2026, imposing a 72.94% subsidy-offset rate on Tosyali Iron Steel Industry Algeria SPA and, by default, all other Algerian producers — a rate based on facts available with adverse inferences after the Algerian government and/or exporters did not fully cooperate with Commerce's subsidy questionnaires. Because USTR determined Algeria is not a "Subsidies Agreement country," the US ITC was not required to make an injury determination, so the CVD order took effect on Commerce's final subsidy determination alone. This is a separate legal track from the parallel antidumping case on the same product (see responds_to) — the AD investigation used a 127.32% margin, the CVD order uses 72.94%, and both stack as cumulative duties on Algerian rebar. Parallel countervailing-duty investigations on Egypt and Vietnam remained at the preliminary stage as of Commerce's 13 January 2026 determinations, with net subsidy rates set at 29.51% (Egypt) and 1.08% (Vietnam); these are provisional cash-deposit rates pending each country's final CVD determination.
The European Commission adopted Communication C(2026) 43 final on 9 January 2026, issuing the first formal interpretive guidelines on the Foreign Subsidies Regulation (FSR, Regulation (EU) 2022/2560). The guidelines codify a four-pillar analytical framework — distortion assessment, public-procurement distortion test, balancing test, and ex officio call-in scope — that DG COMP will apply in every future FSR enforcement proceeding. As the operational blueprint for the FSR regime, the guidelines materially shape Chinese SOE and Gulf SWF EU-market access planning for concentrations, public-procurement tenders, and sub-threshold transactions.
On 6 January 2026 China's Ministry of Commerce issued Announcement No. 1 [2026] "On Strengthening Export Controls on Dual-Use Items to Japan" (商务部公告2026年第1号), the first PRC export-control instrument to single out a named country other than the United States. Effective immediately on publication with no wind-down period, the measure prohibits export of all dual-use items under PRC export-control law where the end-user is the Japanese Ministry of Defense or Self-Defense Forces, the end-use is Japanese military, or — under a novel catch-all standard — the transaction would "enhance Japan's military capabilities." The standard is explicitly extraterritorial, covering transfers of PRC-origin dual-use items through third countries and in-country transfers where the end-user / end-use falls within scope. The political trigger was Japanese PM Takaichi's November 2025 Diet remarks framing a Taiwan contingency as a Japanese "survival-threatening situation" justifying SDF deployment.
On 31 December 2025, China's Ministry of Commerce and General Administration of Customs jointly published Announcement No. 91 of 2025, releasing the 2026 edition of the Catalogue of Dual-Use Items and Technologies Subject to Import and Export Licence Administration, effective 1 January 2026. The update replaces the 2025 catalogue and is issued under the Export Control Law of the PRC and the Regulations on Export Control of Dual-Use Items. Key additions to the export-licensing perimeter include samarium, gadolinium, and lutetium compounds — mid-to-heavy rare earths critical for permanent magnets (EV motors, wind turbines), phosphors (medical imaging, displays), and defence applications — requiring MOFCOM export licences for all covered shipments from 1 January 2026.
Presidential Decree No. 1011 of 31 December 2025 amends the standing Decree No. 302 (25 April 2023) list of foreign-owned assets under "temporary management," adding 100 percent of the shares in Rockwool LLC and 68 percent of the shares in Rockwool-Volga LLC — the Russian operating subsidiaries of Danish insulation producer ROCKWOOL A/S — and transferring control to Construction Assets Development JSC (Развитие Строительных Активов, "RSA"), a newly formed Russian administrator. The decree entered into force on its date of official publication (13 January 2026) despite being signed two weeks earlier, and covers four ROCKWOOL factories (Moscow, Leningrad and Chelyabinsk regions, and Tatarstan) producing heat and sound insulation. ROCKWOOL A/S disclosed in a 13 January 2026 regulatory announcement to Nasdaq Copenhagen that it has determined it has lost control of the four plants.
China's Ministry of Foreign Affairs announced on 26 December 2025 that it is imposing countermeasures under Articles 3, 4, 5, 6, 9 and 15 of the Law of the People's Republic of China on Countering Foreign Sanctions against 20 US defense-related companies and 10 senior executives, in response to the Trump administration's 18 December 2025 announcement of roughly $11.1bn in arms sales to Taiwan — the largest single US weapons package for the island to date. Measures freeze the named entities' assets within China, prohibit organizations and individuals in China from transacting or cooperating with them, and deny visas/entry to the named executives. This is a Foreign Ministry Anti-Foreign Sanctions Law designation, distinct in legal basis from MOFCOM's parallel Unreliable Entity List mechanism used in prior 2025 Taiwan-arms-sale tranches (e.g. the 9 April 2025 six-firm UEL listing).
The Overseas Investment (National Interest Test and Other Matters) Amendment Act 2025 (No 81 of 2025) is the largest rewrite of New Zealand's Overseas Investment Act 2005 since the 2018 residential-land amendment. The Bill (Government Bill 171) was introduced by the Minister of Finance in June 2025, passed all three readings in the House of Representatives, received Royal Assent on 19 December 2025, and was brought into force on 6 March 2026 by the Overseas Investment (National Interest Test and Other Matters) Amendment Act 2025 Commencement Order 2026 (SL 2026/2). The Act replaces the OIA's residual "investor test" discretion with a single statutory national-interest test applied to all "sensitive asset" transactions, introduces a new s 29B repeat-investor mechanism (Treasury does not re-litigate investor risk factors on subsequent applications outside strategically important businesses), creates new military / dual-use technology call-in transactions and critical-direct-supplier call-in transactions (amended s 85), and adds a no-change-of-control transaction category. Administered by The Treasury (policy lead) and Toitū Te Whenua LINZ (operations / case handling), with consent decisions issued by the responsible Ministers.
Section 851 of the FY 2026 National Defense Authorization Act (P.L. 119-60), signed December 18, 2025, prohibits US federal agencies from procuring biotechnology equipment or services from designated "biotechnology companies of concern" (BCCs), and bars federal contractors from using such equipment/services in work performed under federal contracts, grants, or loans. The final enacted text ties initial BCC designations to DoD's existing §1260H Chinese-military-company list (which currently includes BGI and MGI, but not WuXi AppTec or WuXi Biologics) and directs OMB to designate additional BCCs within one year of enactment; operational prohibitions activate 60-90 days after FAR revision, with a five-year grandfather period for pre-existing contracts — enforcement is expected to begin in 2027-28. The legislation is the successor to H.R.8333 (118th Congress, House-passed September 2024 but stalled in the Senate before adjournment) and represents the first enacted US federal-procurement biotech-supply-chain-resilience statute.
China's Ministry of Commerce issued Announcement 2025 No. 72 on 16 December 2025, the final anti-dumping determination concluding a five-year package of definitive duties on imports of certain pork and pig by-products originating in the European Union. Final duty rates range from 4.9% to 19.8% by exporter — significantly lower than the provisional security-deposit rates applied since 10 September 2025 (31–44%), with excess provisional deposits to be refunded. The measure covers fresh, chilled, and frozen pork; edible offal of pigs; pig fat and pig-fat products; and pig intestines, bladders, and stomachs across HS Chapters 02, 05, and 15, and entered into force on 17 December 2025 for a period of five years.
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.