Industrial Policy & Trade Monitor· 2674 actions· ✨ 91 recent

Premier Li Qiang signed State Council Order No. 834 on 31 March 2026 promulgating the "Provisions on Industrial Chain and Supply Chain Security" (18 articles), adopted at the State Council executive meeting on 13 March 2026 and effective on the date of publication. The Provisions are the first dedicated PRC administrative regulation on industrial- and supply-chain security and consolidate authorities drawn from the National Security Law, Foreign Relations Law, Anti-Foreign Sanctions Law, and Foreign Trade Law into a horizontal defensive framework. They establish a cross-agency coordination mechanism spanning roughly 15 central departments (industrial, security, cyberspace, customs and financial regulators) plus provincial governments; create a security-investigation system; and vest broad countermeasure authority over both foreign states (Article 14 — import/export prohibitions and special levies) and foreign organisations and individuals (Article 15 — import/export bans, China-investment bars, transaction prohibitions, entry bars and revocation of work or residence permits, with extension to effectively-controlled subsidiaries). The Provisions also impose compliance, information-sharing, strategic-reserve and emergency-response obligations on PRC organisations and individuals, and authorise requisition, mandated production and directed transportation in the event of supply-chain disruption.

On 18 November 2025, the European Supervisory Authorities (EBA, ESMA, and EIOPA) jointly designated 19 Critical ICT Third-Party Providers (CTPPs) under DORA Article 31, with immediate effect — the first-ever exercise of direct EU financial-regulator supervision over hyperscale cloud and infrastructure providers. The designated entities include Amazon Web Services, Microsoft Azure, Google Cloud, Deutsche Telekom, Oracle, SAP, IBM, Bloomberg LP, London Stock Exchange Group (LSEG), Tata Consultancy Services, and Orange, among others. Designation triggers direct oversight by a lead ESA (EBA for banking-critical, ESMA for capital-markets-critical, EIOPA for insurance-critical) via Joint Examination Teams (JETs), with powers to conduct investigations, carry out on-site inspections, and impose fines of up to 1% of average daily worldwide turnover per day for non-compliance.

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 26 June 2025 President Bola Ahmed Tinubu signed four acts constituting Nigeria's most comprehensive fiscal overhaul in decades: the Nigeria Tax Act 2025 (NTA), Nigeria Tax Administration Act 2025 (NTAA), Nigeria Revenue Service (Establishment) Act 2025, and Joint Revenue Board (Establishment) Act 2025. The NTA consolidates and repeals six core statutes — CITA, PITA, PPTA, VAT Act, CGT Act, and Stamp Duties Act — into a single unified code effective 1 January 2026, while the NTAA standardises assessment, filing, and enforcement procedures across all federal taxes. The two establishment acts restructure the Federal Inland Revenue Service (FIRS) into the Nigeria Revenue Service (NRS) with a broadened mandate and create an empowered Joint Revenue Board to coordinate federal-state fiscal relations.

On 11 April 2025 President Javier Milei signed Decreto de Necesidad y Urgencia 269/2025, published in the Boletín Oficial on 14 April 2025 (edición Nº 35.647). The decree repealed Decreto 28/2023, formally lifting the cepo cambiario — the foreign-exchange restrictions that had been in continuous operation in some form since November 2011. Operative provisions include elimination of the 80/20 export-proceeds-channelling mandate, removal of individual USD purchase and wire-transfer caps, permission for companies to repatriate post-1-January-2025 dividend profits, and replacement of the daily crawling-peg with a band float within a $1,000–$1,400 ARS/USD corridor with BCRA floor/ceiling intervention rules. The measure was coordinated with the IMF Extended Fund Facility (USD 20bn total; USD 15bn 2025 free-availability tranche) approved 11 April 2025, and operationalises the currency-stability guarantee embedded in the RIGI large- investment regime (Law 27.742, July 2024).

The full Pleno of the Corte Suprema de Justicia of Honduras ruled unanimously on 20 September 2024 that Decree 236-2012 (constitutional amendments enabling the ZEDE regime) and Decree 120-2013 (Organic Law of the ZEDEs) violate the "stone-written" Articles 294, 303, and 329 of the Honduran Constitution, which govern territorial organisation, the justice system, and the economic regime respectively. The court applied a retroactive nullatory effect, treating the ZEDE framework as legally void ab initio (from origin). The ruling was published in La Gaceta No. 36,698 on 25 November 2024, conferring erga omnes legal force; the three operational ZEDEs — Próspera (Roatán), Orquídea (Choluteca), and Ciudad Morazán (Cortés) — are formally without statutory basis under Honduran law. The decision triggers a US$10.7 billion CAFTA-DR ICSID arbitration claim (Próspera v. Honduras; preliminary objections decided 26 February 2025) and sets a constitutional precedent for the cost of retroactive SEZ annulment globally.

Three Commission Delegated Regulations (CDR 2024/1772, 1773, 1774) adopted 13 March 2024 and published in the EU Official Journal on 25 June 2024 constitute the first batch of binding Level 2 implementing rules under DORA (Regulation (EU) 2022/2554). CDR 2024/1772 sets ICT incident classification criteria and materiality thresholds for mandatory reporting; CDR 2024/1773 specifies the required content of contractual policies for ICT third-party services supporting critical or important functions; CDR 2024/1774 defines the ICT risk management tools, methods, processes, and policies — including a simplified framework for smaller in-scope entities. All three apply from 17 January 2025 alongside the parent DORA regulation, covering approximately 22,000 EU regulated financial entities.

Regulation (EU) 2023/2675 — the Anti-Coercion Instrument (ACI) — is the EU's first horizontal trade-defence framework explicitly empowering the Union to respond to economic coercion by third countries. Adopted by the European Parliament and Council on 22 November 2023, published in the Official Journal on 7 December 2023, and in force from 27 December 2023, it lets the European Commission (i) determine that a third country is applying economic coercion against the Union or a Member State, (ii) seek dialogue, cessation, and reparation, and (iii) impose Union response measures — including tariffs, services-trade restrictions, IP-rights restrictions, public-procurement restrictions, and FDI restrictions targeting nationals or controlled entities of the coercing state. It complements but does not duplicate the Foreign Subsidies Regulation (which addresses subsidies, not coercion).

Korea's National Assembly passed amendments to Chapter V of the Act on the Adjustment of International Taxes (AITA) on 23 December 2022; promulgated 31 December 2022. The amendment codifies the OECD/G20 Pillar Two GloBE (Global Anti-Base Erosion) rules — specifically the Income Inclusion Rule (IIR) — directly within Korea's existing international-tax statute (Articles 60–83), making Korea the first jurisdiction globally to enact binding primary legislation implementing Pillar Two. The IIR applies to Korean members of MNE groups with consolidated revenue ≥ EUR 750 million for fiscal years beginning on or after 1 January 2024; the Undertaxed Profits Rule (UTPR) was subsequently delayed by the 2024 tax reform bill to fiscal years beginning on or after 1 January 2025. Korea did not initially adopt a Qualified Domestic Minimum Top-up Tax (QDMTT); proposals to add one have been debated in subsequent amendment cycles. The law directly interacts with the K-Chips Act (2023) enhanced investment tax credits: those credits reduce Korean effective tax rates and may trigger Pillar Two top-up exposure unless structured as Qualifying Refundable Tax Credits.

Regulation (EU) 2022/2554 (Digital Operational Resilience Act, DORA) is the EU's first horizontal cyber- and ICT-resilience instrument for the financial sector. Adopted 14 December 2022 and published in the Official Journal on 27 December 2022, it entered into force on 16 January 2023 and applies from 17 January 2025. DORA covers approximately 22,000 EU regulated financial entities across ~20 entity types (credit institutions, insurers, investment firms, CCPs, trading venues, crypto-asset service providers, etc.) under five pillars: ICT risk management, ICT-incident reporting, digital operational resilience testing (including threat-led penetration testing for significant entities), ICT third-party risk management, and information sharing. Structurally novel, DORA establishes the Critical ICT Third-Party Provider (CTPP) oversight regime under which the European Supervisory Authorities (EBA, ESMA, EIOPA) acquire direct supervisory powers over hyperscale cloud providers (AWS, Azure, GCP, Oracle) servicing EU financial entities — the first EU mechanism for ESA direct oversight of non-financial cloud providers.

MOFCOM Order No. 4 of 2020, issued and effective 19 September 2020, establishes the Unreliable Entity List (UEL / 不可靠实体清单) regime — China's primary countermeasure framework for designating foreign companies, organisations, and individuals that are deemed to endanger Chinese national sovereignty, security, or development interests, or that apply discriminatory measures against Chinese entities in violation of normal market principles. The UEL inter-ministerial Working Mechanism, administered through MOFCOM, may impose restrictions or prohibitions on the designated entity's China-related import/export activities, investment in China, and entry or stay of senior personnel in China, as well as fines. Promulgated under the Foreign Trade Law of the PRC and the National Security Law of the PRC, the Provisions serve as the statutory parent for every UEL designation announcement since 2023, and operate as the structural peer of the US BIS Entity List / OFAC SDN architecture and the simultaneously promulgated Anti-Foreign Sanctions Law framework.

On 15 March 2019, the Second Session of the 13th National People's Congress adopted the Foreign Investment Law of the People's Republic of China (FIL), effective 1 January 2020. The statute replaced the prior tripartite FDI regime — the 1979 Equity Joint Venture Law, the 1986 Wholly Foreign-Owned Enterprise Law, and the 1988 Contractual Joint Venture Law (collectively the "Three Laws") — with a unified legal framework covering all foreign investment in China. The FIL establishes a pre-establishment national treatment plus negative-list regime jointly administered by NDRC and MOFCOM, a Foreign Investment Information Reporting System replacing the former case-by-case approval regime, a national security review mechanism (China's CFIUS equivalent, codified at Art. 35), and Art. 22 technology-transfer prohibition protections. The State Council Implementation Regulations (Order No. 723, promulgated 26 December 2019) entered force on the same date as the FIL.

South Korea's Foreign Trade Act (대외무역법, Act No. 5211, enacted 31 December 1986 and repeatedly amended) is the foundational statutory framework of the Republic of Korea's foreign trade and export-control regime. It establishes the Ministry of Trade, Industry and Energy (MOTIE) as the administering authority for foreign trade policy and empowers it to designate strategic items, issue and revoke export licences, operate catch-all controls over non-listed goods destined for WMD-development end-uses, and coordinate with the Nuclear Suppliers Group-administered National Security Authority for Strategic Commerce (NSASC) on Category-0 nuclear items and the Defence Acquisition Programme Administration (DAPA) on military goods. Every MOTIE strategic-items notification (the "Public Notice on Export and Import of Strategic Materials," currently encompassing Categories 1-9 dual-use items harmonised with Wassenaar, MTCR, AG, and NSG) and every MOTIE outbound-investment screening measure derives its legal authority from the Act.