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

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.

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.

President Trump signed Executive Order 14404, "Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy," on 1 May 2026. The order operationalises the country-specific national emergency declared by EO 14380 (29 January 2026) — which had been preserved after the SCOTUS *Learning Resources* vacatur of the IEEPA tariff authority — by establishing a sectoral OFAC blocking regime. Section 2 authorises asset-blocking against any foreign person determined by the Secretary of Treasury (in consultation with State) to operate in Cuba's energy, defense and related materiel, metals and mining, financial services, or security sectors, or "any other sector" subsequently designated. Section 3 suspends entry under INA § 212(f) for covered aliens. Section 4 authorises secondary sanctions against foreign financial institutions that knowingly conduct or facilitate significant transactions for blocked persons, with both correspondent-account and SDN-listing remedies. The EO itself includes no annex of named designations — those are issued by OFAC under separate determinations.

On 23 April 2026, the Council of the European Union adopted the 20th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2026/506 amending Regulation 833/2014 (sectoral sanctions) and Council Regulation (EU) 2026/511 amending Regulation 269/2014 (asset-freeze listings — 120 additional individuals and entities, the largest single tranche in two years). The package operationalises and extends the crypto-sanctions architecture introduced in the 19th package and constructs the legal scaffolding for a future full prohibition on maritime services to vessels carrying Russian crude/petroleum products. Headline measures: (i) full sectoral prohibition on transactions with crypto-asset service providers and exchange platforms established in Russia or Belarus, plus designation of the rouble-backed stablecoin RUBx and the digital rouble (CBDC) on Annex LIII — effective 24 May 2026, with EU support for the digital rouble's development banned outright; (ii) 36 new energy-sector listings spanning upstream extraction, refining and transportation; (iii) prohibition on providing technical, financial, brokering and insurance services to Russia-flagged, Russian-certified or Russian-managed LNG tankers and icebreakers effective 25 April 2026, extending to foreign-flagged vessels operating in Russian interests by January 2027 and culminating in a categorical ban on LNG terminal services to Russian-controlled entities on 1 January 2027; (iv) full transaction ban on 20 Russian banks plus four third-country banks listed for SPFS connectivity / sanctions circumvention; (v) 46 newly listed shadow-fleet vessels and new tanker sale-due-diligence obligations on EU shipping operators; (vi) 58 designations of companies and associated individuals in the Russian military-industrial complex including drone developers/manufacturers; (vii) further Annex IV third-country circumvention enabler listings (China, Hong Kong, Turkey, UAE); (viii) parallel measures against Belarus. Entry into force on 24 April 2026 (day following publication in OJ L_202600506), except for measures with explicit deferred application dates.

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.

Presidential Decree No. 193, signed by President Vladimir Putin on 25 March 2026 and in force from 1 May 2026, prohibits the export from Russia of refined gold bars (аффинированное золото в слитках) with a total weight exceeding 100 grams by individuals, legal entities, and individual entrepreneurs. Narrow exceptions apply for EAEU-destination and non-EAEU-destination movements through designated international airports (Vnukovo, Sheremetyevo, Domodedovo, and Knevichi/Vladivostok) conditional on Federal Assay Office or Federal Border Service permits. The stated rationale — curbing shadow-economy use of bullion as a foreign-currency substitute and closing capital-flight channels — is analytically inseparable from the broader post-2022 Russia counter-sanctions context and the G7 / LBMA delisting of Russian-origin gold.

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

Romania's Government adopted Emergency Ordinance nr. 8/2026 on 24 February 2026, published in the Official Gazette (Monitorul Oficial) nr. 147 of 25 February 2026 and entering into force 1 March 2026, committing a EUR 5 billion (~RON 25 bn) horizontal economic-recovery and productive-investment envelope through 2032 structured around nine state-aid schemes, a 200% corporate R&D expense deduction (High-Tech Research Schema), a RON 1 bn Investment and Development Bank (BID) recapitalization, and a RON 1 bn EximBank export-credit allocation. The ordinance frames Romania's pivot "from consumption to investments as the engine of economic growth" and establishes a Strategic Investment tier (minimum RON 1 bn project value) qualifying for the highest-intensity state-aid eligibility, while introducing a 3% tax-compliance bonus and asset-expensing threshold raised to RON 5,000.

Directive (EU) 2026/470 of 24 February 2026, published in the EU Official Journal on 26 February 2026 and entered into force on 18 March 2026, amends the Corporate Sustainability Reporting Directive (CSRD, Directive (EU) 2022/2464) and the Corporate Sustainability Due Diligence Directive (CSDDD, Directive (EU) 2024/1760). It raises CSRD scope thresholds to undertakings with more than 1,000 employees and more than EUR 450 million net turnover, raises CSDDD scope thresholds to entities with more than 5,000 employees and EUR 1.5 billion turnover (and non-EU entities with EUR 1.5 billion EU turnover), drops the requirement to adopt or put into effect a climate transition plan under CSDDD, and replaces reasonable-assurance with limited-assurance for CSRD reports. CSRD-related provisions must be transposed by 19 March 2027; CSDDD-related provisions by 26 July 2028.

Ethiopia's Council of Ministers adopted Regulation No. 586/2026 on 23 February 2026, published in the Federal Negarit Gazette No. 17 (Year 31), repealing in its entirety the prior Investment Incentives Regulation No. 517/2022. The regulation replaces the legacy 6-15 year corporate income tax holiday regime with a performance-based reduced-tax-rate architecture: 5% for SEZ developers and recognised startups (up to 10 years), 15% for priority sectors including manufacturing, renewable energy, agro-processing, mining value-addition, and technology (2-6 years by sector), and 25% for companies listing on the Ethiopian Securities Exchange. Incentive eligibility requires a minimum USD 10 million capital investment threshold for most priority sectors, and every beneficiary must sign a binding Performance Agreement with the Ethiopian Investment Commission committing to employment, capital-deployment, production, and export targets before incentives are activated — failure to meet targets results in suspension of all incentives with no grace period.

On 7 February 2026 Ukrainian President Volodymyr Zelenskyy signed Presidential Decree No. 103/2026, enacting a National Security and Defence Council (NSDC) decision to apply personal special economic and other restrictive measures (sanctions) against 42 individuals and 35 legal entities based in Russia, Kyrgyzstan and the United Arab Emirates. The tranche specifically targets the "A7" cryptocurrency payment ecosystem, which Ukraine assesses is used to settle payments for components supplied for Russian missile production, alongside wider financial-sector sanctions-circumvention activity. Designation imposes asset freezes and a bar on commercial transactions and investment instruments involving the designees; the decree entered into force on 10 February 2026.

On 29 January 2026 Switzerland's Federal Department of Economic Affairs, Education and Research (WBF) amended Annex 28 of the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), lowering the price cap on Russian seaborne crude oil from USD 47.6 to USD 44.1 per barrel, effective 1 February 2026. The amendment prohibits Swiss-domiciled operators from providing financial and transport (maritime, insurance, brokering) services related to Russian crude oil priced above the new cap. Switzerland is not an EU member but autonomously aligns its Ukraine Ordinance with EU sanctions packages; this cut mirrors the EU's Implementing Regulation 2026/124 and the UK OFSI general licence amendment adopted two weeks earlier under the same six-monthly dynamic-adjustment formula.

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 People's Bank of China announced on 2026-01-15 that it is widening the scope of its Carbon Emission Reduction Support Tool (碳减排支持工具) to cover energy-saving retrofits, green upgrades, and energy green low-carbon transformation projects with direct carbon-reduction effects. The tool operates on a quarterly basis, providing one-year relending funds to financial institutions at below-market rates against qualifying green loans they extend, with total annual operation volume capped at CNY 800 billion (approximately USD 115 billion). PBOC sets each quarter's operation volume based on monetary-policy needs and financial institutions' actual lending to the newly-widened set of supported project categories.

At a 2026-01-15 State Council Information Office press conference, PBOC Deputy Governor and spokesperson Zou Lan announced eight structural monetary-policy measures, including a CNY 500 billion increase to the agriculture/small-business relending-and-rediscount facility (支农支小 再贷款), within which a new CNY 1 trillion private-enterprise relending line (民营企业再贷款) is carved out to target small and medium-sized private firms specifically. The PBOC also cut relending/rediscount rates across all structural tools by 0.25 percentage points effective 2026-01-19 (one-year relending rate down from 1.5% to 1.25%).

On 14 January 2026 the European Commission adopted Implementing Regulation (EU) 2026/124, amending Annex XXVIII to Council Regulation (EU) No 833/2014, lowering the price cap on seaborne Russian crude oil (CN code 2709 00) from USD 47.6 to USD 44.1 per barrel, effective 1 February 2026. This is the first application of the automatic dynamic-adjustment mechanism introduced by the 18th sanctions package (Council Regulation (EU) 2025/1494, July 2025), which re-indexes the cap every six months to 15% below the 22-week trailing average Urals market price. Contracts concluded before 31 January 2026 with cargo offloaded by 16 April 2026 remain subject to the prior USD 47.60/bbl cap. The UK aligned with an equivalent reduction the same day.

Law No. 4 of 15 January 2026 (Gazzetta Ufficiale n. 15 of 20 January 2026, in force 21 January 2026) converted with amendments Decree-Law No. 175 of 21 November 2025 ("Transizione 5.0"). During parliamentary conversion the Camera dei Deputati inserted a new Article 2-bis that materially expands Italy's Golden Power foreign-investment screening regime (DL 21/2012) into the financial, credit, and insurance sectors — the first explicit statutory inclusion of banking and insurance qualifying-holding transactions inside the Golden Power perimeter. The amendment introduces "national economic and financial security" as a public-order criterion alongside the traditional security and public-order profiles, and conditions exercise of special powers in the financial sector on the prior conclusion of pending European prudential and competition proceedings (ECB / EIOPA / EU Commission).

On 15 January 2026 the UK Office of Financial Sanctions Implementation (OFSI), acting under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, amended the 'Oil Price Cap' General Licence (INT/2024/4423849) to lower the price cap on Russian seaborne crude oil from USD 47.60 to USD 44.10 per barrel, effective 23:01 on 31 January 2026. Contracts signed at the prior USD 47.60 cap before that time are subject to a wind-down period, remaining valid provided the oil is offloaded at the port of destination by 22:59 on 16 April 2026. The cut applies the six-monthly dynamic-adjustment formula (15% below the 22-week trailing average Urals price) and was announced in lockstep with the EU's equivalent Implementing Regulation 2026/124.

The US Treasury's Office of Foreign Assets Control designated 18 individuals and entities that make up the "rahbar" shadow-banking networks of sanctioned Iranian banks Bank Melli and Shahr Bank, including Singapore-based Golden Mist PTE Ltd, UAE-based Empire International Trading FZE and HMS Trading FZE, Iran-based Nikan Pezhvak Aria Kish Company and Tejarat Hermes Energy Qeshm, and UK-based Nanshan Ltd. Separately, OFAC designated senior Iranian security officials, including SCNS Secretary Ali Larijani, for their role in the regime's violent crackdown on peaceful protesters that began in December 2025. The financial designations were made under E.O. 13902 (Iran's financial/petroleum/petrochemical sectors) and the human-rights designations under E.O. 13553 and E.O. 13876, in furtherance of NSPM-2; Treasury noted it sanctioned more than 875 persons, vessels, and aircraft under the same maximum-pressure campaign in 2025.

Taiwan's Legislative Yuan passed the Artificial Intelligence Basic Act (人工智慧基本法) on third reading on 23 December 2025, and President Lai Ching-te promulgated the 20-article statute on 14 January 2026, bringing it into force immediately. The Act designates the National Science and Technology Council (NSTC) as the central AI-policy competent authority and codifies seven governance principles — sustainability and well-being, human autonomy, privacy protection and data governance, cybersecurity and safety, transparency and explainability, fairness and non-discrimination, and accountability — that apply to all public-sector AI procurement and high-risk sectoral applications. The statute establishes a statutory foundation for the Taiwan AI Action Plan 2.0, mandates an Executive Yuan National AI Strategy Committee, and provides authority for sector-specific implementing regulations by FSC, NCC, MOHW, and MOTC across finance, telecoms, medical, and autonomous-vehicle AI within a two-year window. As the first national AI governance statute in the Greater China region and the third globally after the EU AI Act and South Korea's AI Basic Act, it frames regulatory expectations for the companies at the heart of the global AI hardware supply chain — TSMC, NVIDIA ODM partners, and advanced-packaging incumbents — that are headquartered or operate substantially in Taiwan.

On 19 December 2025 the Swiss Federal Assembly adopted in final vote the Federal Act on the Screening of Foreign Investments (Bundesgesetz über die Prüfung ausländischer Investitionen, Investitionsprüfgesetz / IPG; popularly the "Lex China", parliamentary business 22.035). The Act introduces Switzerland's first general ex-ante FDI-screening regime: acquisitions of control over Swiss companies active in security-critical sectors by foreign state-controlled investors require prior approval by SECO, with escalation to the Federal Council. The optional- referendum window runs until 17 April 2026; entry into force is not expected before 2027 once implementing ordinances are adopted. Critical sectors named in the Act include military and dual-use goods, electricity grids and generation, water supply, pharma and health, telecommunications, transport infrastructure and financial-market infrastructure.

HM Treasury's Office of Financial Sanctions Implementation (OFSI) published a Russia-regime notice on 18 December 2025 designating five individuals and 19 entities under the Russia (Sanctions) (EU Exit) Regulations 2019. Of the 19 entities, six are based in Russia, eight in the United Arab Emirates, four in Uzbekistan and one in Kyrgyzstan — reflecting OFSI's continued focus on third-country intermediaries used to route sanctioned Russian trade and finance. Designated persons are subject to a full asset freeze and are barred from commercial transactions and investment instruments with UK persons.

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.

On 12 December 2025 the Swiss Federal Council adopted the first tranche of listings aligning with the EU's 19th Russia sanctions package (Council Regulation (EU) 2025/2033, 23 October 2025), amending the Ordinance on Measures in Connection with the Situation in Ukraine and the Belarus Ordinance with effect from 13 December 2025. The decision adds asset freezes and entry/transit bans for 22 natural persons and 42 entities tied to Russia's military-industrial complex, energy sector and shadow-fleet vessel management; extends purchase/sale/insurance bans to over 100 additional tankers; imposes transaction restrictions on 5 Russian banks and 4 Russian-bank branches in Belarus and Kazakhstan for use of specialised financial-messaging services; sanctions Chinese and Hong Kong trading companies and refineries implicated in circumventing the G7 oil price cap; and designates 5 Belarusian persons linked to military-industrial activities. Divestment-exemption deadlines for Swiss persons winding down Russian holdings are extended to end-2026. This is a partial, listings-only tranche — the more substantive measures of the EU's 19th package (Russian LNG import ban, crypto-services prohibition, AI/HPC service bans) were not adopted until the Federal Council's follow-on decision of 25 February 2026.

On 11 December 2025 the Council of the EU presidency, the European Parliament, and the European Commission reached provisional political (trilogue) agreement on the revision of Regulation (EU) 2019/452 establishing a framework for the screening of foreign direct investments into the Union, concluding interinstitutional negotiations on the Commission's proposal of 24 January 2024. The revised regime upgrades the 2019 cooperation-mechanism-only framework into a hybrid harmonised/mandatory regime: all 27 Member States must establish FDI screening mechanisms (replacing the current patchwork in which some Member States have no mechanism at all); mandatory minimum sectoral scope is set EU-wide and covers dual-use items, military equipment, hyper-critical technologies (general-purpose AI with space/defence relevance, quantum technologies, semiconductors), critical raw materials, critical entities in energy/transport/digital infrastructure, electoral infrastructure, and certain financial-system entities; foreign investments routed through EU subsidiaries fall within the perimeter; a shared database prevents Member-State arbitrage; and an optional single electronic-filing portal becomes available if requested by at least nine Member States. Screening decisions remain the exclusive responsibility of the Member State in which the investment is made. Once the Regulation enters into force (after Council and Parliament formal adoption and OJ publication, both pending as of the political-agreement date), the new rules will apply after an 18-month transition period — implementation expected toward the end of 2027.

Morocco's Loi de Finances n° 50-25 for fiscal year 2026, promulgated by Dahir n° 1-25-67 of 10 December 2025 and published in Bulletin Officiel n° 7465 bis of 16 December 2025, sets the FY2026 customs-tariff schedule (continuing the EU Common External Tariff alignment process at 2.5%/17.5%/40% tiers with sector-specific input reductions), amends the fiscal regimes for Zones d'Accélération Industrielle and Casablanca Finance City, and delivers the 2026 tranche of the multi-year IS (corporate-tax) rate-convergence schedule under Framework Law n° 69-19. The law also extends green-investment fiscal accelerators aligned with the EU's Carbon Border Adjustment Mechanism and the EU-Morocco Strategic Partnership on Sustainable Raw Materials Value Chains, and contains phosphate-sector fiscal provisions affecting OCP Group's DAP/MAP/TSP export treatment. Entry into force: 1 January 2026.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) entered into an $11,485,352 settlement with IPI Partners, LLC — a US private-equity data-center fund manager (~$10.5bn AUM) — to resolve 51 apparent violations of the Ukraine-/Russia-Related Sanctions Regulations between July 2018 and June 2022. IPI solicited and accepted two $25 million fund subscriptions in September 2017 and March 2018 from Definition Services, Inc. — a British Virgin Islands entity ultimately owned by Heritage Trust, a Delaware family trust established by sanctioned Russian oligarch Suleiman Kerimov — and continued processing 18 capital calls, 20 distributions, and 13 management-fee payments for four years after Kerimov's April 2018 SDN designation. OFAC simultaneously issued an unusually direct sectoral warning to the private-equity industry, marking the first major OFAC enforcement against a US PE-fund administrator in the data-center / AI-infrastructure segment and the second Kerimov-linked PE/VC settlement of 2025 (after the June 2025 $216M GVA Capital statutory-maximum penalty).

Cyprus Law 194(I)/2025 "The Establishment of a Framework for the Screening of Foreign Direct Investments Law of 2025" was enacted by the House of Representatives and published in the Official Gazette on 14 November 2025, entering into force on 2 April 2026. It establishes Cyprus's first-ever mandatory pre-approval FDI screening regime, designating the Ministry of Finance as the competent Screening Authority and applying to non-EU/EEA/Swiss investors acquiring ≥25% equity or voting rights in Cyprus entities valued at ≥€2 million across covered strategic sectors. The regime implements EU Regulation 2019/452 and includes a Cyprus-specific sectoral extension covering tourism and real estate — addressing golden-passport-era concerns about non-EU capital flows into the island's financial and hospitality economy.

Canada made SOR/2025-228, Regulations Amending the Special Economic Measures (Russia) Regulations, registered 2025-11-06 and announced by Minister Anand on 2025-11-12. The regulations add 13 individuals to Part 1 of Schedule 1, 11 entities to Part 2 of Schedule 1, and 100 vessels (by IMO number) to Schedule 1.1, freezing their Canadian assets and prohibiting dealings. Targets include Russian LNG-trading entities, drone-programme developers, cyber-infrastructure suppliers for hybrid operations against Ukraine, and Kyrgyzstan-based financial enablers (including Capital Bank of Central Asia and the A7 payments platform) used to evade earlier Russia sanctions. The 100-vessel designation targets Russia's "shadow fleet" used to move crude oil, LNG and arms while evading the G7 price cap and flag-state controls.

On 29 October 2025 the Swiss Federal Council amended the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), published as AS 2025 662, completing Switzerland's alignment with the remaining goods, finance and services elements of the EU's 18th Russia sanctions package (Council Regulation (EU) 2025/1494, 18 July 2025) and tightening the parallel Belarus regime. The amendment took effect 30 October 2025 and adds: an export ban covering additional structural-metal, general-purpose-machinery and machine-tool goods; an import ban on further petroleum-oil products and waste/scrap categories; and expanded controls on commercial transactions and investment instruments spanning financial services, investment banking, crude-petroleum trade and motor-vehicle/trailer goods. The Federal Department of Economic Affairs (WBF) had already taken over the measures within its own competence on 12 August 2025; this decision closes the remainder. In parallel, the Federal Council's asset-freeze annexes were extended to 14 individuals and 41 companies/organizations.

The Hrvatski sabor (Croatian Parliament) unanimously adopted the Act on Screening of Foreign Direct Investments on 24 October 2025; the law was published in Narodne Novine 136/2025 and entered into force on 13 November 2025. It establishes Croatia's first-ever statutory horizontal FDI-screening regime, implementing EU Regulation 2019/452 in Croatian law. The Act captures direct or indirect acquisitions by non-EU investors of at least 10 % of share capital, voting rights or property rights in Croatian entities operating in sensitive sectors (defence, dual-use, critical infrastructure, critical minerals, emerging tech, sensitive personal data, energy, transport, health, digital infrastructure, media, financial services). The reviewing authority must decide within 120 days, exceptionally 150 days, of a complete application. Croatia was one of the last EU Member States without a horizontal screening law.

On 23 October 2025, the Council of the European Union adopted the 19th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/2033 amending Regulation 833/2014 (sectoral sanctions), Council Implementing Regulation (EU) 2025/2035 amending Regulation 269/2014 (asset-freeze listings — 22 individuals + 42 entities, total 69 listings), and Council Regulation (EU) 2025/2041 (parallel Belarus measures). The package closes the Russian-LNG import loophole left open by the 18th package and establishes the architectural template for crypto-asset sanctions. Headline measures: (i) full prohibition on imports of Russian-origin LNG into the EU — short-term contracts banned six months from entry into force (effective 25 April 2026), long-term contracts (> 1 year, executed before 17 June 2025) phased out by 1 January 2027; (ii) full transaction ban on Rosneft and Gazprom Neft (tightening prior partial measures); (iii) five additional Russian banks added to Annex XIV transaction ban (Alfa-Bank, MTS Bank among them; effective 12 November 2025); (iv) full transaction bans on the Mir card payment system and the Faster Payments System (SBP), effective 25 January 2026; (v) first-ever EU sanctions on a stablecoin — the rouble-backed A7A5 (issuer + developer designated) — and a Paraguay-based cryptocurrency exchange used as a circumvention rail; (vi) prohibition on EU operators contracting with 11 listed Russian Special Economic Zones (Annex LII), with mandatory divestment from Alabuga (Tatarstan) and Technopolis Moscow effective 25 January 2026 — no five-year wind-down available; (vii) 45 entities added to Annex IV military end-user list (28 Russian + 17 third-country: 12 Chinese/Hong Kong, 3 Indian, 2 Thai); (viii) new export restrictions on electronic components, microelectronics, acyclic hydrocarbons, pneumatic rubber tires and propellant chemicals (~EUR 155 m of EU 2024 exports); (ix) prohibition on supply of AI, HPC, and quantum-computing services to Russian persons (effective 25 November 2025); (x) tourism-services ban (1 January 2026 wind-down); (xi) 117 additional shadow-fleet vessels listed (cumulative 557, exceeding the 18th package's 444); (xii) four Belarus + Kazakhstan banks listed for SPFS use (effective 2 December 2025); (xiii) binding ownership/control definitions added to Reg. 269/2014 (50 % proprietary-rights threshold + eight-criterion control test). Entry into force on 24 October 2025 (day following publication in OJ L_202502033), except for measures with explicit deferred application dates.

On 23 October 2025, the Council of the European Union adopted Council Regulation (EU) 2025/2041 (amending Regulation (EC) No 765/2006) and Council Decision (CFSP) 2025/2040 (amending Decision 2012/642/CFSP), widening the EU's Belarus restrictive-measures regime in lockstep with the 19th Russia sanctions package adopted the same day. The package widens the export ban to industrial goods (salts, ores, rubber articles, tyres, millstones, construction materials, electronic components, rangefinders, propellant chemicals, metals/oxides/alloys), extends the import ban to all acyclic hydrocarbons, introduces a new prior-licensing requirement for services supplied to Belarus, its government, or public bodies, and mirrors the Russia regime's space, AI, and high-performance/ quantum-computing service restrictions. A companion instrument, Council Implementing Regulation (EU) 2025/2039, adds 5 new asset-freeze listings (2 individuals + 3 entities, including JSC Holography Industry, Horizont Holding, and ICT Horizont). Entered into force 24 October 2025.

FinCEN issued a final rule under Section 311 of the USA PATRIOT Act (31 U.S.C. § 5318A) prohibiting US covered financial institutions from opening or maintaining a correspondent account for, or on behalf of, Cambodia-based Huione Group, a foreign financial institution found to be of primary money-laundering concern. Treasury determined that Huione Group and its subsidiaries — including Haowang Guarantee, Huione Pay PLC, and Huione Crypto — laundered at least $4 billion of illicit proceeds between August 2021 and January 2025, including funds tied to North Korean cyber-heist actors and Southeast Asian "pig-butchering" investment-scam compounds. The rule also imposes a special-due-diligence requirement on US covered institutions to guard against indirect access via foreign correspondent accounts. Effective November 17, 2025.

On 15 October 2025 the UK Foreign, Commonwealth & Development Office, acting under the Russia (Sanctions) (EU Exit) Regulations 2019, designated 39 entities and specified 51 vessels — including, for the first time, Russia's two largest integrated oil majors PJSC Rosneft Oil Company and PJSC Oil Company Lukoil — for supporting Russia's energy, defence and financial sectors. 51 vessels (44 identified as "shadow fleet" tankers) were specified for transporting Russian crude oil and LNG in evasion of the G7 price cap. The package also introduced a ban on importing oil products refined in a third country from Russian-origin crude, closing a refined-product loophole in the price-cap regime.

Loi n° 2025-16 du 27 septembre 2025 portant Code des Investissements, published in Journal Officiel du Sénégal n° 7853 du 2 octobre 2025, is the first major horizontal recodification of Senegal's investment framework in 21 years, fully repealing and replacing the Loi n° 2004-06 du 6 février 2004 portant Code des Investissements. Enacted under the Faye-Sonko administration as part of the September 2025 modernisation package (companion to the parallel General Tax Code recodification), the law introduces a digital single-window with a 10-business-day processing guarantee, territorial fiscal and customs stability regimes differentiated by region (3 years for Dakar/Thiès, 5 years for other regions), expanded eligible-sector coverage, and statutory local-content integration mandates to strengthen SME participation. Existing investor protections — national treatment, free capital transfer, and nationalisation/expropriation guarantees — are maintained and modernised. The law structurally aligns the investment framework with Vision Sénégal 2050 sustainable-development requirements.

The US Treasury's Office of Foreign Assets Control designated Burma-based arms procurement company Royal Shune Lei Company Limited, its three Burmese executives, and two North Korean nationals linked to the Korea Mining Development Trading Corporation (KOMID) for operating an arms-trafficking and revenue-generation network supporting DPRK weapons of mass destruction and ballistic missile programs. Royal Shune Lei brokered sales of aerial bomb guidance kits, bombs, and airborne monitoring equipment to Burma's military junta on behalf of KOMID starting in 2022. Designations were made under Executive Order 13687 (DPRK), Executive Order 13551 (DPRK arms trade), and Executive Order 14014 (Burma), blocking all US-jurisdiction property of the six designated parties and barring US persons from transactions with them.

On 20 September 2025 President Anura Kumara Dissanayake, in his capacity as Minister of Finance, Planning and Economic Development, gazetted the "Colombo Port City (Guidelines on the Grant of Exemptions or Incentives to Businesses of Strategic Importance) Regulations, No. 1 of 2025" in Extraordinary Gazette No. 2454/62 under the Colombo Port City Economic Commission Act, No. 11 of 2021. The new framework materially compresses the SEZ's headline tax-incentive envelope: Primary BSI awards fall from a 25-year full Inland Revenue Act exemption plus a 10-year half-rate follow-on to a single one-time exemption of up to 15 years, and Secondary BSIs lose the prior 25-year full-or-partial relief in favour of a concessionary 7.5% corporate-income-tax rate for four years from commercial operation. VAT exemption is not carried over into the new framework. The regulation is effective from publication, runs for five years, and supersedes Regulation No. 02 of 2023.

The US Treasury's Office of Foreign Assets Control designated two Iranian financial facilitators — Alireza Derakhshan and Arash Estaki Alivand — along with more than a dozen Hong Kong- and UAE-based individuals and entities for operating a shadow-banking network that laundered proceeds from Iranian oil sales through front companies and cryptocurrency. The designated addresses account for over $600 million in total inflows, including more than $100 million in cryptocurrency purchases tied to oil sales between 2023 and 2025. Proceeds are alleged to benefit the IRGC-Qods Force and Iran's Ministry of Defense and Armed Forces Logistics (MODAFL). This is the second round of OFAC sanctions targeting Iran's shadow-banking infrastructure since National Security Presidential Memorandum 2 (NSPM-2) directed a maximum-pressure campaign on Iran in February 2025.

New Zealand's 32nd sanctions round under the Russia Sanctions Act 2022 (Russia Sanctions Amendment Regulations (No 4) 2025, SL 2025/195) lowered the price cap on Russian-origin crude oil (HS 2709) from US$60/bbl to US$47.60/bbl, a roughly 21% cut, aligning New Zealand with the EU, UK and Canada's most recent price-cap reductions. The same instrument designated 19 individuals and entities plus 19 vessels, including Russia's GRU cyber unit 29155 (implicated in malware attacks on Ukrainian government networks), actors involved in chemical-weapons use and disinformation, additional "shadow fleet" tankers, alternative payment providers, and third-country facilitators based in North Korea and Iran supporting Russia's war effort.

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

On 20 August 2025 the UK government, acting under the Russia (Sanctions) (EU Exit) Regulations 2019, designated three individuals and five entities — OJSC Capital Bank of Central Asia, Grinex LLC, CJSC Tengricoin, Old Vector LLC (all Kyrgyzstan-based) and Altair Holding SA (Luxembourg-based) — for helping Russia evade Western financial sanctions via opaque Kyrgyz banking channels and cryptocurrency rails. The designations target the A7A5 rouble-backed stablecoin network, which the FCDO says moved USD 9.3bn in transactions over four months, and the Grinex/Meer crypto exchanges used to convert and route the proceeds; designated parties face UK asset freezes and trust-services prohibitions.

Act L of 2025 (2025. évi L. törvény) is the Hungarian National Assembly statute that elevates a set of war-emergency government decrees — including the foreign-investment screening regime previously embedded in Government Decree 561/2022 — to permanent statutory level. Promulgated in Magyar Közlöny and entered into force on 19 August 2025, the Act preserves Hungary's "Second Regime" of FDI screening operating in parallel with the General Regime (which implements EU Reg 2019/452 since 2019). The Second Regime applies to a broad set of strategic sectors — energy, transport, communications, telecoms, pharmaceuticals, food processing, defence, financial services and healthcare — and requires approval from the Minister of National Economy for qualifying acquisitions (direct or indirect majority, ≥5% interest, ≥3% in listed companies, or ownership/operation of strategic infrastructure) where transaction value reaches HUF 350 million (~EUR 890,000). Notification is due within 10 days of signing; the MoE originally had 30 business days (extendable +15 calendar days). The Act also entrenches the Hungarian state right of first refusal on photovoltaic generation companies (NACE 35.11'08, excluding sub-50 kVA household installations), exercised through MNV Zrt. The Special Regime is structurally distinct from the General Regime and represents Hungary's peer to the German AWG §§55-62, French Décret 2014-479, Dutch Wet Vifo, and Italian Golden Power. Amended by Act XCIII of 2025 (in force 17 December 2025), which extended the MoE screening deadline to 45 business days and excluded bank-financing security arrangements from notification.

On 14 August 2025 OFAC re-designated the cryptocurrency exchange Garantex Europe OU under its cyber authority (E.O. 13694, as amended) for processing over USD 100 million in transactions tied to ransomware and darknet-market actors since 2019, and designated its successor exchange Grinex — created by former Garantex staff to move customer deposits and continue operations after a March 2025 US Secret Service-led takedown of Garantex's infrastructure. OFAC also designated three Garantex executives, the A7A5 ruble-backed stablecoin issuer Old Vector (Kyrgyzstan), and Russian settlement-platform firm A7 and its subsidiaries A71 and A7 Agent — entities linked to sanctioned Moldovan oligarch Ilan Shor and sanctioned Promsvyazbank — for supplying the A7A5 token used to compensate Garantex customers and route funds through Grinex.

On 12 August 2025 the Swiss Federal Department of Economic Affairs, Education and Research (WBF) amended the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), published as AS 2025 497, adopting — within its own delegated competence and ahead of the full Federal Council decision — an interim tranche of measures aligning Switzerland with the EU's 18th Russia sanctions package (Council Regulation (EU) 2025/1494, 18 July 2025). The amendment lowers the Russian-crude price cap and updates the associated Annex 28 price-threshold table, extends export prohibitions on transport services, adds port-access restrictions covering 105 additional shadow-fleet vessels, and widens controls on commercial transactions and investment instruments for Russian financial institutions. It also extends asset-freeze listings to entities in China, Hong Kong, Singapore, Mauritius, Azerbaijan, India and the UAE implicated in circumvention. The measure took effect 12 August 2025. The Federal Council closed out the remaining goods, finance and services elements of the 18th package on 29 October 2025 (see responds_to).