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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.

Japan's Diet passed the Foreign Exchange and Foreign Trade Act (FEFTA) 2026 Amendment on 29 May 2026; the law was promulgated on 5 June 2026. The amendment represents the most significant overhaul of Japan's inbound FDI screening regime since FEFTA was first applied to national-security transactions in 2019. Three structural additions: (1) indirect-acquisition screening — extends mandatory prior-notification to acquisitions of Japanese sensitive-sector companies effected through intermediate holding structures or offshore parent vehicles, closing the principal gap exploited by Chinese and GCC SWF investors via SPV chains; (2) call-in powers — grants the Minister of Finance authority to open a review up to ten years retroactively where an acquisition was not pre-notified or where circumstances have materially changed since clearance, directly analogous to CFIUS § 721(b)(1)(D) retroactive jurisdiction; (3) cross-ministerial "Japan CFIUS" consultation framework — formally institutionalises a standing inter-agency committee (Finance, METI, MoD, NPA, MIAC) modelled on the US CFIUS committee, replacing the prior ad-hoc inter-ministerial process. Cross-ministerial and indirect-acquisition provisions entered into force immediately on promulgation (5 June 2026); remaining Cabinet-Order-level implementing provisions to follow within one year.

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.

On 15 April 2026 Japan's Ministry of Economy, Trade and Industry (METI) published the interim summary "Manufacturing Base Strengthening Report" from the Study Group on Strengthening Manufacturing Base in Light of Geopolitical Risks. The report frames Japan's manufacturing base as the source of national power and proposes shifting economic-security support for "autonomy assurance" from "point" measures to "area"-wide measures — expanding the scope of Specified Critical Materials under the 2022 Economic Security Promotion Act (ESPA) beyond narrowly defined inputs to cover foundational petrochemicals (ethylene, propylene, methanol, synthetic rubber) and process-industry technologies (casting, forging), plus components for emerging technologies (humanoid-robot actuators and sensors, lasers for quantum computing). It is the cornerstone framework document operationalising METI's FY2026 strategic-budget package (~¥3.07 trillion overall envelope; ~¥1.23 trillion specifically for semiconductors and AI, including ¥150bn for Rapidus and ¥387.3bn for AI development) as Japan's coordinated response to deepening Chinese export-control pressure on dual-use items, gallium/germanium, graphite, antimony and heavy rare earths.

Turkish President Erdoğan signed Presidential Decision No. 11068 on 16 March 2026, published in the Resmî Gazete on 17 March 2026, establishing a mandatory pre-clearance regime for the transit passage and re-export of controlled military items through Türkiye's customs territory. Covered items include military vehicles and defence equipment, weapons and ammunition and their spare parts, military explosives, and dual-use technologies associated with these categories, as defined under Law No. 5201. Any entity seeking to move such goods through Türkiye must obtain a "uygunluk yazısı" (compliance letter) from the Ministry of Trade, which reviews applications in consultation with relevant public institutions. The measure directly operationalises Türkiye's response to sustained US pressure over Iran-related sanctions evasion via Turkish transit corridors and entity-list additions naming Türkiye-based diversion networks.

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.

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 16 January 2026, the US Treasury's Office of Foreign Assets Control designated 21 individuals and entities and identified one vessel for transferring oil products, procuring weapons and dual-use equipment, and providing financial services to Iran-backed Ansarallah (the Houthis). Designated parties — oil-trading and exchange companies, a shipping/logistics facilitator, and front-company operatives — are based in Yemen, Oman, and the UAE, and are accused of running an oil-sales and financial- facilitation network that Treasury says generates the Houthis over $2 billion in annual illicit revenue. The action was taken pursuant to Executive Order 13224 (as amended) and builds on a multi-year cadence of prior OFAC designations against Houthi leaders, smugglers, financiers, and weapons-procurement suppliers.

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.

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.

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.

On 9 December 2025, China's Ministry of Commerce (MOFCOM) and General Administration of Customs jointly issued Announcement No. 79 of 2025, reinstating an export-licence management system for ~300 HS-coded steel products effective 1 January 2026. Exporters must obtain a per-contract licence supported by a manufacturer-issued product quality inspection certificate; licences are issued by MOFCOM (for centrally-administered SOEs) and provincial / sub-provincial commerce departments. The regime is the first reinstatement of Chinese steel-export licensing in 16 years (since 2009) and applies the export-licensing instrument — previously used for critical minerals and dual-use goods — to a non-critical bulk commodity for the first time.

ECOFIN on 12 December 2025 adopted a Council Implementing Decision approving the 4th amendment to Poland's National Recovery and Resilience Plan (Krajowy Plan Odbudowy, KPO), following Commission proposal C(2025) 7998 final of 19 November 2025. The amendment modifies 80 measures within the plan while keeping Poland's total financial contribution under the EU Recovery and Resilience Facility (RRF) unchanged at EUR 25,276,853,716 in grants, alongside an estimated EUR 20.6 bn REPowerEU chapter envelope. Adopted in parallel with amendments for Austria, Cyprus, Czechia, France, Greece, Latvia, Malta, Portugal and Slovenia, this amendment continues the structural pivot — first opened by the May 2025 third amendment — that allows Poland to redirect post-COVID recovery funds toward defence-industrial and dual-use spending given the NATO eastern-flank context.

MOFCOM Announcement No. 68 of 2025 (商务部公告2025年第68号), issued on 26 October 2025, sets the application requirements and procedures for state-owned trading enterprises (STEs) authorised to export tungsten, antimony and silver during the 2026-2027 cycle. The notice formalises a quota review and joint-approval gate operated through the Key Export Supervision Catalog under MOFCOM's foreign-trade STE authority — distinct from the Export Control Law dual-use regime used in Announcement No. 10 of February 2025. Silver is added for the first time to the STE-managed list, framed by MOFCOM as defence of strategic supply for defence, electronics and photovoltaics. Approved-exporter lists were published in a follow-on review-results notice; the new regime applies to export shipments dated 1 January 2026 onwards.

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.

The US Treasury's Office of Foreign Assets Control designated 21 entities and 17 individuals across three procurement networks supplying Iran's Ministry of Defense and Armed Forces Logistics (MODAFL) and its subordinate weapons producers. The networks sourced ballistic-missile guidance components (accelerometers, gyroscopes, MEMS) for the Shahid Bakeri Industrial Group and Shahid Hemmat Space Group, dual-use radar/missile-guidance electronics routed through Hong Kong and China for Shiraz Electronics Industries, and helicopter parts — including a US-origin helicopter — routed through Germany, Türkiye, Portugal and Uruguay for Iran Helicopter Support and Renewal Company (PANHA). The action is Treasury's first nonproliferation-sanctions tranche following the 27 September 2025 UN Security Council "snapback" reimposing pre-JCPOA sanctions on Iran.

India's Directorate General of Foreign Trade (DGFT) issued Notification No. 31/2025-26 on 23 September 2025, revising Appendix-3 of Schedule-II of the ITC(HS) Export Policy to add a new Category 7 — "Certain Emerging Technologies and related items" — to the SCOMET (Special Chemicals, Organisms, Materials, Equipment and Technologies) list. Category 7 brings under export-licence control: quantum-computing systems (≥34 qubits with controlled error rates), cryogenic CMOS integrated circuits, advanced lithography tools (≤45 nm minimum resolvable feature), additive-manufacturing equipment under vacuum, and related software/technology. The notification took effect 30 days from issuance, on 23 October 2025, and is the first new SCOMET category created since the list's last major restructure, aligning India's strategic-trade-control regime with parallel US BIS, Wassenaar Arrangement, and EU dual-use list updates.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to add 32 entities to the Entity List, with the largest bloc — 23 entries — under the destination of China, plus India (1), Iran (1), Singapore (1), Taiwan (1), Turkey (3), and the United Arab Emirates (2). The rule also removed two addresses from one Russian entry (Intertech Rus LLC) and made 27 typographical corrections to existing entries. Several Chinese additions — including Shanghai Fudan Microelectronics, Sino IC Technology, GMC Semiconductor (Wuxi), and Chinese Academy of Sciences units (National Time Service Center; Aerospace Information Research Institute) — were given footnote 4 designations, extending the EAR's foreign-direct-product (FDP) reach to non-US-origin items destined for Russian military end use. Three Turkish entries (Atempo, EB Teknoloji, Dentun Elektronik) and one Indian entry (AR Sales Pvt Ltd) were footnote-3 Russian Procurement Entity designations. The rule is a final rule effective September 12, 2025; all listed parties are subject to a license requirement for all items subject to the EAR with a presumption-of-denial review policy.

Commission Delegated Regulation (EU) 2025/2003, adopted by the European Commission on 8 September 2025, published in the Official Journal on 14 November 2025 and entering into force on 15 November 2025, amends Annex I of Regulation (EU) 2021/821 to implement the 2024 multilateral decisions of the Wassenaar Arrangement, MTCR, Australia Group, and NSG. The most extensive EU semiconductor-equipment additions since the 2021 framework took effect: ALD, epitaxial deposition, lithography, EUV pellicles/masks/reticles, SEM, and etching equipment, plus tighter controls on quantum computers, advanced FPGAs/ICs for AI training, additive-manufacturing, and cryogenic/superconducting components. The regulation is the EU-side update layer of the Western dual-use export control architecture, structurally aligned with the US BIS advanced- computing/SME packages and the Netherlands DUV-licensing regime.

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).

On 8 September 2025, the UK Ministry of Defence published the Defence Industrial Strategy 2025 — "Making Defence an Engine for Growth" (CP 1388) — the first comprehensive cabinet-level UK defence industrial strategy in over a decade and the sector plan for Defence under the UK Modern Industrial Strategy umbrella (IS-8). The strategy was published alongside the Strategic Defence Review 2025 and operationalises the largest sustained defence- spending increase since the Cold War (rising to 2.6% of GDP by 2027 with ambition to 3% in the next Parliament). It defines six priority outcomes (growth, backing UK businesses, defence innovation, resilient industrial base, procurement transformation, enduring partnerships); establishes UK Defence Innovation (UKDI) within the MOD with a ringfenced £400m budget to accelerate dual-use technology; identifies priority defence capabilities (combat air, complex weapons, directed-energy weapons, next- generation land and maritime systems) plus dual-use sub-sectors (quantum, drones/autonomy, space, AI, cyber, engineering biology, advanced connectivity); and flags resilience priorities in steel, construction, energetic materials, batteries, semiconductors and rare earths.

On 8 August 2025, Ukraine's President signed Decree No. 595/2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against Russian state nuclear corporation Rosatom and its international corporate network. Sanctions were applied to 18 individuals and 17 legal entities identified as involved in attempts to integrate the occupied Zaporizhzhia Nuclear Power Plant into Russia's grid, participation in the seizure of the Chornobyl NPP, production and servicing of dual-use nuclear equipment, and export of enriched uranium through Rosatom subsidiaries registered in Switzerland, Cyprus, the Netherlands, and Finland. Named entities include Uranium One Holding N.V. (Netherlands), Rosatom Finance Ltd (Cyprus), and JSC Kirov-Energomash (Russia).

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.

Taiwan's Ministry of Economic Affairs International Trade Administration (MOEA-ITA) amended the Strategic High-Tech Commodities (SHTC) export-control Entity List on 10 June 2025 (announced 15 June 2025) under Article 13 of the Trade Act, adding 601 new entities — including Huawei Technologies Co. Ltd. and Semiconductor Manufacturing International Corp. (SMIC) plus 599 additional entities domiciled in China, Russia, Iran, Pakistan and Myanmar. Taiwanese exporters (TSMC, UMC, ASE, KYEC and downstream suppliers) must obtain pre-export government licences for direct or third-party shipments of any SHTC-listed item to the listed entities; the action expands Taiwan's total entity-list population to ~10,844 entities. Two follow-on amendments tightened the regime further: a +279-entity expansion on 18 September 2025 and an 18-item commodity-list expansion on 18 November 2025 covering advanced 3D printers, semiconductor manufacturing equipment, electron microscopes and quantum-computing hardware.

On 20 May 2025, the Council of the European Union adopted the 17th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/932 amending Regulation 833/2014 (sectoral measures) and Council Implementing Regulation (EU) 2025/933 implementing Regulation 269/2014 (asset-freeze listings). Sectoral measures include the largest single-package expansion of the shadow-fleet port-access ban (additional vessel listings layered on top of the 153 designations carried over from the 16th package), the addition of 31 entities — including third-country (Chinese, Turkish, UAE, Hong Kong) firms — to the Annex IV list of military end-users barred from receiving dual-use and critical industry goods (covering chemical precursors used in missile propellants and spare parts for high-precision machine tools), and reinforced anti-circumvention "no-Russia" clause obligations on EU exporters. Council Implementing Regulation (EU) 2025/933 imposes asset freezes on 17 additional individuals and 58 additional entities, including shadow-fleet vessels and operators, a major Russian oil company, Russian military/defence-sector firms, and persons involved in the looting of Ukrainian cultural heritage. Parallel hybrid-threat, human-rights, and chemical-weapons designations were adopted under separate horizontal regimes on the same day. The Council noted EU shadow-fleet and oil-price-cap measures had reduced Russian revenues by approximately EUR 38 billion since introduction. Entry into force on 21 May 2025 (day following publication in the Official Journal).

Japan's Ministry of Economy, Trade and Industry (METI) overhauled the catch-all export-control framework under the Foreign Exchange and Foreign Trade Act (FEFTA) — the first comprehensive review of Japan's catch-all controls in 12 years (since 2013). Cabinet decisions were taken on 25 March 2025 and 4 April 2025 with METI's consolidated announcement on 9 April 2025; the amended Cabinet Order entered into force on 9 October 2025. The reform (i) splits catch-all-controlled items into "core items" (high dual-use risk, including certain semiconductors and machine tools) and a general catch-all tier, (ii) adds a new end-user requirement alongside the existing end-use requirement and extends both from UN-arms-embargo countries only to "general countries" (everywhere outside Group A), materially expanding the perimeter of items requiring METI export licences for general-country end-users including China, and (iii) introduces an "informed" condition for exports to Group A countries — once METI notifies an exporter of a defined risk pattern, a Group A export becomes licence-required, addressing transit-export-circumvention to Russia. Structurally distinct from the 23-category equipment-specific 2023 amendment (2023-03-31-japan-meti-semi-equipment-export-controls); this is the underlying horizontal catch-all reform and brings Japan's framework closer to US BIS EAR catch-all controls.

On 24 February 2025, the third anniversary of Russia's full-scale invasion of Ukraine, the Council of the European Union adopted the 16th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/395 amending Regulation 833/2014 and a cluster of associated regulations (2025/389, 2025/390, 2025/392, 2025/398, 2025/401). The package introduces the EU's first import ban on Russian primary aluminium (CN 7601) under a 275 kt transition quota (~80% of 2024 volumes), expels 13 additional Russian banks from the SWIFT financial-messaging system, adds 74 vessels (153 total) to the shadow-fleet port-access and services ban, prohibits any temporary storage of Russian crude and petroleum products in EU ports, bans transactions with major Russian airports (Moscow Vnukovo, Zhukovsky) and ports (Astrakhan, Makhachkala, Ust-Luga, Primorsk, Novorossiysk) used for sanctions circumvention, extends flight-ban coverage to 25 third-country airlines operating domestic Russian routes, and adds 83 asset-freeze listings (48 individuals, 35 entities) under Regulation 269/2014. Parallel measures cover Belarus and the non-government-controlled areas of Ukraine. Entry into force on 25 February 2025.

MOFCOM and the General Administration of Customs jointly issued Announcement No. 10 [2025] on 4 February 2025, imposing dual-use export-licence controls on items related to tungsten, tellurium, bismuth, molybdenum and indium under the Export Control Law and Dual-Use Items Export Control Regulations. The controls cover metals, alloys, powders, compounds and related processing technologies across roughly 25 listed item categories (41 HS 10-digit codes). The measure is global in scope but was issued the same day China announced 10-15% retaliatory tariffs on US LNG, coal, crude and farm equipment in response to the Trump administration's 10% fentanyl-tariff hike — extending the MOFCOM critical-minerals control regime beyond gallium/germanium/graphite/antimony/heavy-REEs.

On 16 December 2024 the Council of the European Union adopted Council Regulation (EU) 2024/3192 amending Regulation (EU) 833/2014, the 15th package of restrictive measures against Russia. The package adds 84 asset-freeze listings (54 individuals and 30 entities) under Regulation 269/2014 — for the first time including fully-fledged designations of seven Chinese individuals and entities supplying drone components, machine tools, and dual-use goods to the Russian military-industrial complex. It expands the EU shadow-fleet vessel- ban list by 52 tankers (total 79), activates the standalone EU hybrid- threats sanctions regime with its first 16-individual / 3-entity designations, extends the wind-down derogation for divestment from Russian subsidiaries to 31 December 2025, and reinforces anti- circumvention contractual clauses on EU exporters of dual-use goods.

China's Ministry of Commerce announced on 3 December 2024 (MOFCOM Announcement No. 46 of 2024) a formal ban on dual-use exports to the United States of gallium, germanium, antimony and superhard materials including diamond and cubic boron nitride. The measure also imposed strict end-use review on graphite exports to the US, with extra scrutiny of military end-uses. It came one day after BIS issued a major export- control package on 2 December 2024 expanding controls on Chinese semiconductor equipment and adding 140 entities to the Entity List, and was framed by MOFCOM as a national- security countermeasure.

Premier Li Qiang signed State Council Decree No. 792 on 19 October 2024 promulgating the Regulations of the People's Republic of China on Export Controls for Dual-Use Items, with effect from 1 December 2024. The regulation, organised in six chapters and 50 articles, consolidates the previously fragmented nuclear / biological / chemical / missile dual-use control regimes into a single State Council framework operationalising the 2020 Export Control Law. It introduces a control-list / temporary-control / watchlist architecture, a statutory end-user / end-use commitment regime, transit / transhipment / re-export controls, extraterritorial reach over PRC items downstream, and explicit linkage to the Anti-Foreign Sanctions Law. On 15 November 2024 MOFCOM, MIIT, GAC and SCA jointly issued Announcement No. 51 of 2024 publishing the consolidated Dual-Use Items Export Control List with a unified five-character ECCN-style coding system, also effective 1 December 2024.

Cabinet Resolution No. 97 of 2024 is the implementing regulation of UAE Federal Decree-Law No. 43 of 2021 on Commodities Subject to Non-Proliferation. It operationalises the UAE's horizontal dual-use export-control regime, empowering the Executive Office for Control & Non-Proliferation (EOCN) to designate prohibited and restricted goods on the National Control List and to issue export/transit/re-export permits within 20 working days. The Control List covers nuclear materials, chemicals and precursors, electronics, telecommunications, sensors and lasers, navigation systems, avionics, marine and aerospace equipment, propulsion systems, and "national controlled commodities" (armoured vehicles, autonomous equipment). This is the regulatory architecture under which post-G42 advanced AI-chip outbound flows from the UAE are licensed.

The US Bureau of Industry and Security (BIS) final rule (89 FR 68544; FR Doc 2024-19130) added 123 entities under 131 entries to the Entity List with destinations Russia (63), China (42), Iran (11), Turkey (8), and one each in Canada, Cyprus, Kazakhstan, Kyrgyzstan, Crimea Region of Ukraine, Ukraine, and the United Arab Emirates. The dominant rationale is Russia-diversion enforcement: Chinese, Turkish and other third-country firms (e.g., MAK Logistics, Megatek Ltd., Wellgo International, AllChips Limited, Chipgoo Electronics) named for supplying U.S.-origin electronics and dual-use items to Russian industry and military, plus designation of large numbers of Russian military manufacturers (e.g., JSC 75 Arsenal, FSE Aleksinsky Chemical Plant) as military end users. License requirement is "all items subject to the EAR" with policy/presumption of denial; case-by-case for EAR99 food and medicine to certain Russian military end users. Effective on publication 2024-08-27.

On 29 June 2024 the Council of the European Union adopted Council Regulation (EU) 2024/1865 and Council Decision (CFSP) 2024/1864, amending Regulation (EC) No 765/2006 to extend Belarus's sanctions regime so that it mirrors the restrictive measures already in force against Russia, closing routes used to circumvent the Russia sanctions via Belarus. The package bans the import of gold, diamonds, helium, coal and other mineral products (including crude oil) originating in or exported from Belarus; bans the import of goods and technology on the EU Common Military List if of Belarusian origin; extends the export ban on dual-use goods, oil-refining and LNG-liquefaction equipment, maritime-navigation goods and luxury goods to Belarus; prohibits transit via Belarus of EU-exported firearms and ammunition; and broadens the road-transport ban. The measures entered into force on 1 July 2024, the day after publication in the Official Journal.

On 24 June 2024 the Council of the European Union adopted Council Regulation (EU) 2024/1745, the 14th package of restrictive measures against Russia, amending Regulation (EU) 833/2014. The package introduces the EU's first targeted measures against Russian LNG (a ban on EU-port transhipment to third countries after a 9-month transition, and a prohibition on EU investment and goods/services exports to Russian LNG projects under construction such as Arctic LNG 2 and Murmansk LNG), bans EU entities outside Russia from using the SPFS Russian financial-messaging system, designates 27 named "shadow-fleet" tankers under a new vessel-specific port-access ban, and imposes a "best-efforts" obligation on EU parents to ensure non-EU subsidiaries do not engage in sanctions circumvention. It adds 116 new listings (69 individuals, 47 entities), including third-country circumvention enablers, to the asset-freeze and travel-ban regime.

BIS final rule (FR Doc 2024-13148, 89 FR 51644, RIN 0694-AJ87) expanding the Export Administration Regulations' Russia and Belarus sanctions architecture. Effective 12 June 2024 (most provisions) and 16 September 2024 (the EAR99 enterprise-software paragraph at §746.8(a)(8)), the rule introduces a new licence requirement for thirteen named categories of EAR99 enterprise software (ERP, CRM, BI, SCM, EDW, CMMS, project management, PLM, BIM, CAD, CAM, ETO) destined for Russia or Belarus; permits address-only Entity List designations to capture high-diversion addresses; adds eight Hong Kong addresses to the Entity List; and refines the Russia/Belarus Industry Sector Sanctions and Foreign Direct Product (FDP) rule. Released the day before the G7 Italy summit alongside coordinated OFAC, State, and Treasury actions that together designated 300+ persons and entities.

Japan's National Diet enacted the Act on the Protection and Use of Critical Economic Security Information (重要経済安保情報の保護及び活用に関する法律, Act No. 27 of 2024) on 10 May 2024; it was promulgated on 17 May 2024 and came into full operation on 16 May 2025. The law establishes Japan's first peace-time economic-security clearance regime extending to private-sector employees. It designates "Critical Economic Security Information" (CESI) covering threat-intelligence on critical-infrastructure cyber attacks, regulatory-review information on essential infrastructure, and vulnerability data on critical-product supply chains; mandates Cabinet Office "適性評価" (suitability assessment) for cleared personnel; and imposes criminal penalties of up to five years' imprisonment for unauthorised disclosure. The CESI Act complements the 2022 Economic Security Promotion Act (ESPA), closing the information-protection gap and aligning Japan's framework with Five Eyes and EU partners for joint R&D and dual-use cooperation.

The Defence Trade Controls Amendment Act 2024 (C2024A00021) received Royal Assent on 8 April 2024 and created three new criminal offences in the Defence Trade Controls Act 2012: section 10A (supply of Defence and Strategic Goods List technology in Australia to a non-exempt foreign person); section 10B (secondary supply of DSGL Part 1 Munitions or Part 2 Dual-Use Sensitive/Very Sensitive goods or technology outside Australia when originally exported from Australia); and section 10C (provision of DSGL Part 1 services to foreign nationals outside Australia). All three offences carry maximum penalties of 10 years imprisonment or 2,500 penalty units (~A$782,500), or both. The offence framework commenced 1 September 2024 with a six-month compliance-transition period; criminal liability attached from 1 March 2025. The Act also codifies AUKUS-partnership exemptions, carving out supplies to and from citizens and permanent residents of the United Kingdom and United States, underpinning the licence-free trilateral technology-transfer environment sought under AUKUS Pillar 2.

Latvia's Saeima adopted on 27 March 2024 amendments to the National Security Law (Nacionālās drošības likums), entering into force on 24 April 2024, that widen the perimeter of foreign-investment and ownership transactions subject to Cabinet of Ministers pre-clearance over "companies of significance to national security." The amendments expand the universe of regulated subjects beyond registered companies to include foundations and associations, tighten the rules on beneficial-ownership disclosure, and bring additional sensitive activities — energy security including LNG-terminal acquisitions, electronic communications, cybersecurity, and critical-raw-materials processing — under the regime, while clarifying Cabinet authority to impose conditions or unwind transactions retroactively. The law functions as Latvia's horizontal FDI-screening instrument under the EU-wide cooperation framework of Regulation 2019/452.

On 29 February 2024 Switzerland's WBF decided to align with the EU's 13th Russia sanctions package by amending the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), effective 1 March 2024 at 18:00 CET. The amendment adds over 100 individuals and nearly 90 entities — mainly Russian military-industrial-complex firms and suppliers of DPRK-sourced weapons to Russia — to the asset-freeze and designation lists, and extends the dual-use/military-technology export ban to 27 additional companies believed to be circumventing existing controls.

On 23 February 2024, two years after Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Council Regulation (EU) 2024/745, amending Regulation (EU) No 833/2014 and comprising the EU's 13th Russia sanctions package. It adds new CN codes to the export-ban annexes (dual-use and advanced-technology goods) and adds 27 entities — including firms based in China, Hong Kong, India, Sri Lanka, Serbia, Kazakhstan, Thailand and Turkiye — to the list of parties barred from any exemption from the export ban, on the basis they are assessed to be supporting Russia's military-industrial complex via circumvention routes. Asset-freeze listings (106 individuals, 88 entities) under the parallel Council Decision took effect 23 February 2024; the sectoral trade measures took effect 24 February 2024.

Bulgaria's National Assembly adopted on 22 February 2024 amendments to the Investment Promotion Act establishing the country's first horizontal foreign direct investment screening mechanism, published in State Gazette No. 20 on 8 March 2024 and entering into force on 12 March 2024. The regime implements EU Regulation 2019/452 by creating an Interdepartmental Screening Council with a 45-day decision window over non-EU investments meeting a 10 % equity stake or €2 million threshold in critical-infrastructure, dual-use, advanced-technology, media, and financial-infrastructure sectors, with no threshold for investments by Russian or Belarusian persons or in oil and petroleum activities. Non-compliance and false declarations carry fines of 5 % of investment value, with a minimum BGN 50,000.

Ireland's Screening of Third Country Transactions Act 2023 (Act No. 28 of 2023), signed into law on 31 October 2023 and commenced on 6 January 2025 via S.I. No. 651 of 2024, establishes Ireland's first-ever mandatory inbound FDI screening regime. The Act empowers the Minister for Enterprise, Tourism and Employment to assess, condition, or prohibit transactions by third-country investors (non-EU/EEA/Switzerland) exceeding a EUR 2 million cumulative threshold in targets operating across critical infrastructure, critical technologies, dual-use items, supply of critical inputs, sensitive personal data, and media freedom. A 90-day standstill period applies during Ministerial determination, with criminal sanctions and transaction-voiding powers available for non-compliance.

China's Ministry of Commerce and General Administration of Customs jointly announced (Announcement No. 33 of 2023) export-licensing controls on graphite products, effective 1 December 2023. The regime covers natural flake graphite and products thereof (including spherical graphite and graphite powder used in lithium-ion battery anodes) as well as high-purity, high-hardness, and high-strength synthetic graphite materials. Exporters must obtain dual-use-item licences from MOFCOM citing end-user and end-use; licences are granted at MOFCOM's discretion. The announcement came three days after the 17 October 2023 BIS advanced-chip-controls expansion, continuing the proportional-response pattern established with Ga/Ge in July.

Sweden's first horizontal foreign-direct-investment screening regime. Lag (2023:560) om granskning av utländska direktinvesteringar — promulgated (utfärdad) by the Ministry of Justice on 21 September 2023 on the basis of Government Bill 2022/23:116, and entered into force on 1 December 2023 — establishes mandatory ex-ante notification to Inspektionen för strategiska produkter (ISP) for direct or indirect acquisitions of voting rights of ≥10%, 20%, 30%, 50%, 65%, or 90% in Swedish entities conducting "skyddsvärd verksamhet" (protected business activities). The protected-activity perimeter is defined by Förordning (2023:624) and the ISP listing across seven sub-categories: essential services, security-sensitive activities, critical raw materials/metals/ minerals, sensitive location and personal data, military equipment, dual-use goods, and emerging or strategically protected technologies. Both EU and non-EU investors are within scope. Unnotified transactions are void by operation of law and may carry administrative fines of SEK 25,000 to SEK 100 million. From 1 Dec 2023 to 29 Nov 2024 ISP processed 1,206 notifications, opened 24 deeper screenings, approved 11, approved 5 with conditions, and prohibited 1 transaction.