Industrial Policy & Trade Monitor· 2662 actions· ✨ 89 recent

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 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 12 February 2026, Ambassador Jamieson Greer of the Office of the United States Trade Representative oversaw the signing of the US-Taiwan Agreement on Reciprocal Trade (ART) in Washington, DC. The instrument was signed under the auspices of the American Institute in Taiwan (AIT) and the Taipei Economic and Cultural Representative Office in the United States (TECRO). Headline terms: (i) US IEEPA reciprocal-tariff rate on Taiwan reduced from 20% to 15% and Section 232 auto-parts/timber/lumber rate cut from 25% to 15%; (ii) Taiwan eliminates or reduces 99% of its tariff barriers on US goods, most immediately and the remainder phased over three years; (iii) Taiwan side commits ~USD 85bn in directed purchases through 2029 (USD 44.4bn LNG/crude, USD 15.2bn civil aircraft and engines, USD 25.2bn power equipment); (iv) sectoral chapters covering tariffs, non-tariff barriers, digital trade, economic security, and high-tech supply-chain resilience. Operationally linked to the 15 January 2026 AIT-TECRO Memorandum of Understanding on investment, under which Taiwan pledges USD 250bn in direct Taiwanese-enterprise investment in the US plus USD 250bn in Taiwan-government credit guarantees (USD 500bn total) to fund US-side industrial parks/clusters in advanced semiconductors, energy, and AI manufacturing. Entry into force is conditional on Taiwan's Legislative Yuan completing its review.

On 6 February 2026 Presidents Trump and Modi announced a framework for an Interim Trade Agreement that resets the bilateral tariff posture installed in 2025. Two operative instruments: (i) an executive order signed 6 February eliminating, effective 7 February 2026, the additional 25% IEEPA "Russian-oil" duty on Indian imports imposed by EO 14329 (27 August 2025), conditional on India's commitment to cease buying Russian crude and to expand defence cooperation; and (ii) reduction of the EO 14257 reciprocal-tariff rate on India from 25% to 18% on listed product categories (textiles and apparel, leather and footwear, plastics and rubber, organic chemicals, home décor, artisanal products, certain machinery), to take effect on finalisation of the Interim Agreement. India commits to eliminate or reduce tariffs on all US industrial goods and a wide range of agricultural products (DDGs, red sorghum, tree nuts, fresh and processed fruit, soybean oil, wine, spirits) and to purchase >USD 500bn of US energy, ICT, coal, aircraft and aircraft parts, and precious-metals products over five years. The framework also commits the parties to negotiating "robust, ambitious, and mutually beneficial digital trade rules" and to addressing non-tariff barriers in medical devices, ICT import licensing, and food/agricultural standards. US tariff reductions on Indian generic pharmaceuticals, gems, diamonds, aircraft parts, and certain automotive components are flagged as contingent on completion of the full Interim Agreement.

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.

On 22 December 2025 the FCC's Public Safety and Homeland Security Bureau released Public Notice DA-25-1086, adding to the Covered List (under section 1709 of the FY2025 NDAA) all unmanned aircraft systems (UAS) and UAS critical components produced in a foreign country, plus communications and video-surveillance equipment/services produced by DJI Technologies and Autel Robotics (and their subsidiaries, affiliates, and licensing/JV partners). The designation is comprehensive by scope — every foreign-made drone from consumer quadcopters to large uncrewed systems, with no size/performance carve-out — and blocks the FCC from granting any new equipment authorization to covered UAS/components going forward. Previously authorized models already in the US market are not revoked. A follow-on Public Notice (DA-26-22, 7 January 2026) narrowed the scope with a temporary exemption (see amendments).

On 13 November 2025, the United States and the Republic of Korea released a Joint Fact Sheet reaffirming the July 2025 announcement of the Korea Strategic Trade and Investment Deal — the first standalone US-Korea trade-and-investment agreement since the 2012 KORUS FTA. USTR issued the implementing Federal Register notice (90 FR 55964, Notice 2025-21940) on 3 December 2025, effective 4 December 2025, with retroactive HTSUS application to 1 November 2025 for autos and auto parts and to 14 November 2025 for reciprocal-tariff goods, timber, lumber, derivatives, and certain aircraft and aircraft parts. On the US tariff side: (i) the country-specific IEEPA reciprocal tariff on Korean originating goods is set at the higher of the KORUS FTA / MFN rate or 15% (parallel to the Japan and EU framework deals); (ii) the Section 232 tariffs on autos, auto parts, timber, lumber and wood derivatives are reduced to 15% (no incremental duty when the pre-existing KORUS/MFN rate already meets or exceeds 15%); (iii) Korean exports of qualifying goods on the Potential Tariff Adjustments for Aligned Partners (PTAAP) list are exempt from reciprocal tariffs (covering generic pharmaceuticals and unavailable natural resources); (iv) Section 232 pharmaceuticals capped at 15%; semiconductors granted MFN-style "no less favourable" treatment in any future sectoral deal. On the investment side, Korea commits to a USD 350bn package: USD 150bn into US shipbuilding ("Approved Investments") plus USD 200bn into US strategic industries via a separate Strategic Investments MOU, with annual currency-funding cap of USD 20bn. Non-tariff commitments include streamlined US biotech approvals on the Korean side, US meat and cheese market access, fair treatment for US digital services, removal of Korea's 50,000-unit cap on US vehicles meeting FMVSS, and joint WTO support for the moratorium on customs duties on electronic transmissions.

On October 31, 2025, Bulgaria's National Assembly voted 135-4 (42 abstentions) to adopt a decision introducing a temporary measure restricting the export and intra-EU supply of petroleum products — chiefly diesel and aviation fuel — to all destinations, including fellow EU member states. The measure took effect around November 1, 2025 upon publication. Gasoline was excluded because domestic production exceeds internal demand. The ban is a direct domestic-supply-security response to US OFAC's October 22, 2025 SDN designation of Lukoil (see responds_to), whose Burgas refinery supplies roughly 80% of Bulgaria's fuel market; lawmakers cited the risk that sanctions exposure could disrupt Lukoil's export activity and drain the volumes needed to cover domestic demand. Exemptions cover refuelling of ships and aircraft and deliveries to NATO and EU member-state armed forces under the common defence policy.

India's Ministry of Defence signed a contract worth over Rs 62,370 crore (excluding taxes, ~USD 7.5 billion) with Hindustan Aeronautics Limited (HAL) on 25 September 2025 for 97 Light Combat Aircraft (LCA) Mk1A — 68 single-seat fighters and 29 twin-seat trainers — for the Indian Air Force. The acquisition falls under the "Buy (India-IDDM)" (Indigenously Designed, Developed and Manufactured) category of the Defence Acquisition Procedure 2020 and carries an indigenous-content requirement of over 64%, incorporating 67 additional indigenous items compared with the prior January 2021 LCA Mk1A contract. Deliveries begin 2027-28 and run over six years, supported by a vendor base of roughly 105 Indian component manufacturers.

On 8 September 2025, Spanish Prime Minister Pedro Sánchez announced a nine-measure package against Israel over the Gaza war, the centrepiece being urgent approval of a Royal Decree-Law to permanently codify in law the arms embargo Spain had applied de facto since October 2023 — a total ban on buying and selling arms, ammunition, military equipment and dual-use goods with Israel, plus a ban on port transit of fuel for the Israeli military and a ban on Israeli state aircraft carrying defence material transiting Spanish airspace. The package also bans importing, advertising and marketing products originating from Israeli settlements in the occupied West Bank and Gaza. The Council of Ministers formally approved the measure as Real Decreto-ley 10/2025 on 23 September 2025; it was published in the BOE on 24 September 2025 (BOE-A-2025-18831) and validated by Congress on 8 October 2025 (178–169). Spain's Ministry of Economy, Trade and Business separately disclosed that 219 defence-material export/import licences to Israel had been denied since October 2023, against a bilateral trade backdrop of roughly €50M in Spanish arms exports to Israel (Jan 2023–Jun 2024) and at least €54.4M in Spanish imports of Israeli arms/munitions (Oct 2023–May 2025, DataComex code 93).

President Trump signed Executive Order 14323, "Addressing Threats to the United States by the Government of Brazil," on 30 July 2025 (published in the Federal Register on 5 August 2025 as FR doc 2025-14896). Invoking IEEPA and the National Emergencies Act, the order declared a country- specific national emergency citing "policies, practices, and actions" of the Lula government — including the criminal prosecution of former president Jair Bolsonaro, asserted infringement of the free-expression rights of US persons via DSA-style platform-content rules, and retaliatory measures targeting US digital firms — as constituting an "unusual and extraordinary threat" to US national security, foreign policy, and economy. The EO imposed a 40% additional ad valorem duty on Brazilian-origin goods effective for entries on or after 12:01 a.m. EDT on 6 August 2025; stacked on top of the 10% baseline reciprocal rate from EO 14257/14326, the cumulative rate reached 50% for non- exempt goods. Annex I exempted civil aircraft and parts, orange juice, certain machinery, certain metals, and energy/energy products. The EO was amended on 20 November 2025 (effective for entries on or after 13 November 2025) to exempt 238+ HTSUS codes for agricultural products (beef, tropical produce, nuts, coffee, cocoa, cassava derivatives, etc.) following initial Trump-Lula bilateral negotiations on 6 October 2025. The IEEPA-tariff component was terminated by EO of 20 February 2026 ("Ending Certain Tariff Actions") within hours of the SCOTUS 6-3 ruling in *Learning Resources, Inc. v. Trump* holding that IEEPA does not authorize the imposition of tariffs.

On 27 July 2025, President Trump and European Commission President Ursula von der Leyen reached political agreement at Turnberry, Scotland, on a Framework Agreement on Reciprocal, Fair and Balanced Trade. The framework was formalised in a Joint Statement published on 21 August 2025 by the White House and DG TRADE. The deal establishes a 15% all-inclusive (MFN + Section 232) US tariff ceiling on the vast majority of EU originating goods — including autos, pharmaceuticals, semiconductors, lumber, and chemicals — replacing the threatened 20-30% reciprocal tariff trajectory under EO 14257 (April 2025). Steel and aluminium are excluded from the 15% ceiling and remain at the 50% Section 232 rate pending negotiation of a quota solution. In return, the EU commits to: (i) eliminate tariffs on all US industrial goods, (ii) preferential market access for a wide range of US agricultural and seafood products, (iii) suspension of its rebalancing countermeasures under Reg 2025/778 (suspension effective 7 August 2025), (iv) expected energy offtake of $750bn (LNG, oil, nuclear) through 2028, (v) at least $40bn in US AI chip purchases, and (vi) facilitation of $600bn in additional EU corporate investment into the US through 2028. Effective from 1 September 2025, the US applies MFN-only treatment (no 15% top-up) to: aircraft and parts, generic pharmaceuticals and ingredients, chemical precursors, cork, and certain unavailable natural resources. The framework is not legally binding but anchors the bilateral architecture; it is the largest-economy ART-programme deal alongside US-UK, US-Japan, US-Korea, US-Taiwan, and US-Indonesia.

On 4 February 2025, President Donald J. Trump signed National Security Presidential Memorandum/NSPM-2, "Imposing Maximum Pressure on the Government of the Islamic Republic of Iran, Denying Iran All Paths to a Nuclear Weapon, and Countering Iran's Malign Influence." The memorandum reimposes the first- term "maximum pressure" framework, directing the Secretaries of State and Treasury and the Attorney General to (i) drive Iran's exports of crude oil and petroleum products — including to the People's Republic of China — to zero; (ii) review and modify or rescind sanctions waivers and general licences (notably the Chabahar port waiver benefiting India); (iii) sanction shadow-fleet vessels, intermediaries, refineries (including PRC "teapot" refiners) and oil traders facilitating Iranian energy exports; and (iv) lead a diplomatic isolation campaign including a snapback of UN Security Council sanctions under JCPOA Resolution 2231 paragraph 11. Since promulgation, OFAC has designated 1,000+ Iran-related persons, vessels and aircraft and four PRC independent ("teapot") refiners alleged to have processed sanctioned Iranian crude. The DOJ is also directed to pursue impoundment of Iranian oil cargoes and seizure of Iranian assets to satisfy US-court terrorism-victim judgments.

The Bureau of Industry and Security (BIS) established a new Iran Foreign Direct Product (FDP) rule and created Supplement No. 7 to Part 746 of the EAR, effective 24 February 2023, to address Iran's supply of UAVs to Russia for use against Ukraine. The rule adds twelve HTS-6 codes covering UAV-relevant components — aircraft engines, processors, capacitors, memories, and radio navigation equipment — many of which are EAR99 items outside existing ECCNs, requiring a new licence for exports and reexports to Iran. Simultaneously, the rule expands the existing Russia/Belarus FDP rule to cover these same items, closing a gap where foreign-produced items derived from US technology could transit to Russia via Iran without triggering EAR licence requirements.

On 16 December 2022 the Council of the European Union adopted Council Regulation (EU) 2022/2474, the 9th package of restrictive measures against Russia, amending Regulation (EU) 833/2014. It entered into force on publication the following day (17 December 2022). The package extends the prohibition on new EU investment from the Russian energy sector to the Russian mining and quarrying sector, bans exports of aircraft and drone engines and their parts to Russia (and to any third country that could re-supply drones to Russia), adds 168 entities to the sectoral export- control annex covering chemicals, nerve agents, night-vision and radio- navigation equipment, electronics and IT components, and prohibits EU advertising, market-research, product-testing and technical-inspection services to Russia. A parallel Council Decision/Implementing Regulation designated a further 141 individuals and 49 entities to the EU asset-freeze and travel-ban list.

The UK laid the Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 (UKSI 2022/748), in force 5 July 2022, extending the Belarus sanctions regime to mirror measures already imposed on Russia over the invasion of Ukraine. The regulations ban export to Belarus of dual-use goods and technology for all purposes, and of critical-industry goods and technology including quantum-computing components, microelectronics, marine and navigation equipment, and aircraft/aircraft parts. They widen existing import bans to cover a greater range of petroleum/mineral products and prohibit import of arms, iron and steel products originating in or consigned from Belarus, and extend financial sanctions barring Belarusian companies from issuing debt or securities in London or obtaining loans from UK banks, and barring UK persons from providing financial services to the National Bank of the Republic of Belarus or the Belarusian Ministry of Finance.

The Act on the Promotion of Ensuring National Security through Integrated Implementation of Economic Measures (Law No. 43 of 2022), enacted 18 May 2022, establishes a four-pillar framework: (1) supply-chain resilience for "specified critical products," (2) security of critical infrastructure, (3) state-backed development of "specified critical technologies," and (4) non-disclosure of nationally sensitive patents. A December 2022 Cabinet Order designated 11 product categories as specified critical products, including semiconductors, storage batteries, permanent magnets, cloud programs, LNG, critical minerals, machine tools, and aircraft parts. Competent ministries must publish stable-supply plans, can fund private-sector surveys, and may provide subsidies to qualifying firms.

The Bureau of Industry and Security (BIS) issued a final rule expanding license requirements under the EAR for all items on the Commerce Control List (CCL) destined for Russia and Belarus, retroactively effective April 8, 2022. The rule also removes certain license exceptions that previously allowed aircraft-related transactions involving Belarus to proceed without authorization. Issued in direct response to Russia's continued aggression in Ukraine and Belarus's role in enabling it, this measure substantially tightens the multilateral export- control perimeter first established by BIS in late February 2022.

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

The Sanctions and Anti-Money Laundering Act 2018 (SAMLA, Chapter 13) received Royal Assent on 23 May 2018 and established the UK's autonomous post-Brexit sanctions legal framework. Part 1 empowers Ministers (FCDO, HM Treasury) to impose financial, trade, immigration, aircraft, and shipping sanctions by statutory instrument for purposes including UN compliance, national security, foreign-policy objectives, and promotion of human rights and democracy. Part 2 grants Ministers authority to make AML and counter-terrorist-financing regulations aligned with FATF standards, previously derived from EU Anti-Money-Laundering Directives. SAMLA is the parent enabling statute for every UK sanctions regime in force post-Brexit, including 30+ thematic and geographic regulations covering Russia (SI 2019/855), Iran, DPRK, Belarus, Myanmar, Syria, Venezuela, cyber, chemical weapons, global anti-corruption, and global human rights; under SAMLA, OFSI (HM Treasury) holds civil monetary-penalty and criminal-referral enforcement powers. Structurally peer to US IEEPA, EU Council Regulation framework, CN AFSL 2021, and JP FEFTA as the G7+CN foundational sanctions-statute cluster.