Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

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.

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 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.

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.

On 18 July 2025, the Council of the European Union adopted the 18th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/1494 amending Regulation 833/2014 (sectoral measures), Council Implementing Regulation (EU) 2025/1476 implementing Regulation 269/2014 (asset-freeze listings), Council Decision (CFSP) 2025/1495 (vessel listings), and Council Regulation (EU) 2025/1472 (parallel Belarus measures). The package is the largest energy-sector escalation since 2022 and pivots from new-perimeter creation toward enforcement and circumvention closure. Headline measures: (i) the Russian-crude price cap is lowered from USD 60 to USD 47.6 per barrel with a new automatic dynamic mechanism re-indexing the cap to global oil prices every six months at a 15 % discount to the 22-week trailing average (effective 3 Sep 2025, with a transitional exemption to 18 Oct 2025 for pre-20 Jul 2025 contracts compliant with the prior cap); (ii) full transaction ban extended to 22 additional Russian banks, bringing the total cut off from the EU financial system to 45; transaction ban extended to third-country financial institutions and crypto-asset service providers facilitating circumvention; (iii) full transaction ban on Nord Stream 1 and Nord Stream 2 pipelines; (iv) import ban on refined oil products derived from Russian crude processed in third countries; (v) 105 additional vessels added to the shadow-fleet port-access ban (cumulative total 444); (vi) 26 new entities added to Annex IV military end-user list (15 Russian + 11 from China/Hong Kong/Turkey); (vii) Council Implementing Regulation 2025/1476 lists 14 individuals + 41 entities under asset-freeze, including a major Indian refinery (Nayara Energy, part-owned by Rosneft), three Chinese suppliers of battlefield goods, shadow-fleet operators, and entities involved in the deportation of Ukrainian children; (viii) parallel Belarus complementary measures via Regulation 2025/1472. Wind-down periods vary: 90 days for oil-price-cap contracts; banking-software wind-down to 30 Sep 2025; trade-goods wind-downs Oct 2025–Jan 2026 by category. Entry into force on 19 July 2025 (day following publication in the Official Journal), except for measures with explicit deferred application dates.

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

Between 22 and 28 February 2022 — coinciding with Russia's full-scale invasion of Ukraine — OFAC issued a Financial Services Sectoral Determination and four directives under Executive Order 14024 of April 15, 2021. Together they authorise designation of any person operating in Russia's financial sector, prohibit US persons from trading Russian sovereign debt, bar US banks from maintaining correspondent accounts for designated Russian financial institutions (Sberbank, Alfa-Bank and others), prohibit new investment in certain Russia-related entities, and block all transactions involving the Central Bank of the Russian Federation, the National Wealth Fund, and the Ministry of Finance — effectively freezing approximately USD 640 billion in Russian sovereign reserves held in Western financial systems. The package was formally published in the Federal Register on 31 May 2022.

On 8 October 2020, the US Treasury's Office of Foreign Assets Control (OFAC) determined that section 1(a)(i) of Executive Order 13902 (10 January 2020) applies to the financial sector of the Iranian economy, exposing non-US persons that operate in or knowingly facilitate significant transactions with that sector to secondary sanctions. Concurrently, OFAC designated eighteen Iranian banks (sixteen under E.O. 13902, one as an owned-or-controlled affiliate, and Hekmat Iranian Bank under E.O. 13382 non-proliferation authority). After a 45-day wind-down, the secondary-sanctions exposure became effective on 22 November 2020. The determination was formally republished in the Federal Register on 1 October 2025 (FR Doc 2025-19123) under Trump 2.0's maximum-pressure restoration; the underlying economic measure dates to the 2020 action.

The International Emergency Economic Powers Act of 1977 (IEEPA, Title II of Pub. L. 95-223, 91 Stat. 1626, codified at 50 U.S.C. §§ 1701–1708) was signed by President Carter on 28 December 1977 and grants the President sweeping authority to declare a national emergency with respect to "any unusual and extraordinary threat, which has its source in whole or substantial part outside the United States, to the national security, foreign policy, or economy of the United States" — and then to investigate, regulate, direct, compel, nullify, void, prevent, or prohibit any transaction in, or involving, foreign exchange, banking transfers, importing, exporting, or dealings in property by persons subject to US jurisdiction. IEEPA is the parent enabling statute for every OFAC-administered autonomous sanctions program (Russia, Iran, DPRK, Venezuela, Cuba, Syria, Belarus, Myanmar, cyber, Global Magnitsky, Hong Kong, ICC, and others) as well as the legal basis for the entire Trump-era IEEPA-tariff regime (EO 14193–14195 fentanyl tariffs, Canada/Mexico/China; EO 14257 reciprocal-tariff framework; EO 14323 Brazil; EO 14380 Cuba; EO 14382 Iran; and the US-India interim tariff agreement). Between 1977 and 2025 Presidents invoked IEEPA in 77 national-emergency declarations; of these, 7+ directly parent IPTM-filed implementing actions, with ~dozens of OFAC SDN designation actions tracing their legal root to this statute.