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Structured register of government actions in the geoeconomic space — export controls, tariffs, sanctions, FDI screening, subsidies, industrial-policy laws — cross-referenced into the country, minerals, and ETF surface. Charter: docs/IPTM_CHARTER.md.
Severity 1-5 is the qualitative impact rating (1=minor, 5=structural). The bilateral-trade-grounded quant scorer is the next IPTM milestone. RBI (Register Breadth Index) is a complementary structural-breadth indicator from scripts/py/iptm/breadth.py; divergence between RBI and severity is itself informative (high-sev / low-RBI = strategic chokepoint; low-sev / high-RBI = broad but shallow). Every action has at least one primary source URL. Verify-or-don't-file. See also themes, timeline, graph, sankey, map, country exposure, sector exposure, material exposure (+ graph), weekly briefs, portfolio scan, escalation monitor, trans-shipment hubs. Internal triage tools (RSS-poller candidate feed, source-feed health) live under /admin/candidates + /admin/sources. Subscribe via Atom feed (accepts ?country=CN, ?material=lithium, ?issuer=BIS, ?type=export_control, ?etf=SOXX, ?company=NVDA, ?minSeverity=4, ?year=2026, ?q=…) or pull /api/iptm/actions.
On 7 September 2026 the UK made the Iran (Sanctions) (Amendment) Regulations 2026 (SI 2026/983), laid before Parliament 8 September 2026 and due to come into force 29 September 2026. The instrument substantially rewrites the Iran (Sanctions) Regulations 2023 and the Iran (Sanctions) Regulations 2019, adding new financial restrictions (bans on loans, credit and joint ventures with Iranian manufacturing, oil/gas, petrochemical and uranium interests; a ban on UK banks opening accounts or representative offices for Iranian banks; an insurance/reinsurance ban; a ban on trading Iranian government bonds issued after the regulation date), new trade-control chapters covering gold/precious metals/diamonds, energy-related goods and services, and sectoral software, new import bans on Iranian gold, oil, petrochemicals and natural gas, and new aircraft/shipping parts restricting Iranian cargo flights, chartering of specified vessels, and UK port entry and ship registration for sanctions-evading vessels.
On 2 May 2026, MOFCOM issued Announcement No. 21 of 2026 — the first concrete prohibition order ever issued under China's 2021 "Rules on Counteracting Unjustified Extra-territorial Application of Foreign Legislation and Other Measures" (Blocking Rules) and the Anti-Foreign Sanctions Law (AFSL). The order prohibits any Chinese organisation, individual, or foreign party operating in China from recognising, enforcing, or complying with US sanctions imposed under Executive Orders 13902 and 13846 against five Chinese independent ("teapot") refineries — Hengli Petrochemical (Dalian) Refining Co., Ltd., Shandong Shouguang Luqing Petrochemical Co., Ltd., Shandong Jincheng Petrochemical Group Co., Ltd., Hebei Xinhai Chemical Group Co., Ltd., and Shandong Shengxing Chemical Co., Ltd. — all designated by OFAC for purchasing Iranian crude. The announcement is the first operational test of the framework built up across the AFSL (2021), the AFSL Implementation Regulations (Order 803, March 2025), and State Council Order 835 on Countering Foreign Unlawful Extraterritorial Jurisdiction (April 2026), and creates a direct compliance conflict for banks, insurers, traders, and shipping companies operating in or with China that had been winding down their exposure to the listed refineries.
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 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.
President Trump issued five Presidential Determinations on 20 April 2026 under Section 303 of the Defense Production Act of 1950 (50 U.S.C. § 4533), invoking the authority granted by Executive Order 14156 (Declaring a National Energy Emergency, signed 20 January 2025). The five determinations cover: (1) domestic petroleum production, refining, and logistics; (2) large-scale energy and energy-related infrastructure development, manufacturing, and deployment; (3) natural gas transmission, processing, storage, and LNG capacity; (4) coal supply chains and baseload power generation; (5) grid infrastructure, equipment, and supply chain. Each determination authorises the relevant Cabinet Secretary (primarily Energy) to use DPA §303 powers — direct loans, loan guarantees, purchase commitments, and equity investments — to expand domestic capacity in the named category.
On 12 March 2026 Senegal's Primature held a press conference releasing mid-term findings of the National Commission for the Re-evaluation and Renegotiation of Petroleum, Gas, and Mining Contracts, created in August 2024 under Prime Minister Ousmane Sonko's reform programme. The Commission identified a 1,075.9 billion FCFA shortfall in the mining sector — concentrated in unpaid taxes/royalties and unauthorised tax exemptions at ICS (Industries Chimiques du Sénégal) — and announced the termination of four offshore oil-exploration blocks (Djifer Offshore, Kayar Offshore, Saint-Louis Offshore, Rufisque Offshore). Renegotiation of the Greater Tortue Ahmeyim (GTA) gas project, operated by BP with Kosmos Energy and Woodside as partners on the Senegal-Mauritania maritime border, is under active examination; the Primature projects 900 bn FCFA in incremental fiscal revenue 2026-2040 from the contract revision programme. This is Senegal's first major instance of retroactive resource-contract review under the Sonko-Faye government and establishes the legal-political baseline for subsequent contract renegotiations across the 27 mining contracts and remaining hydrocarbon licences under Commission review.
On 13 February 2026 President Bola Ahmed Tinubu signed Executive Order No. 9 of 2026 directing all Production Sharing Contract operators and contractors to remit Royalty Oil, Tax Oil, Profit Oil, and Profit Gas directly to the Federation Account, bypassing prior NNPC Limited intermediated collection. The order simultaneously eliminates NNPC Limited's 30% management fee on profit oil/gas, suspends the 30% Frontier Exploration Fund deduction, and redirects Gas Flare Penalty proceeds to the Federation Account — materially walking back the fiscal architecture established under Petroleum Industry Act 2021 §§ 9 and 53. An Implementation Committee chaired by the Minister of Finance was established to operationalise the order and resolve disputes.
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.
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 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.
On October 22, 2025, the US Treasury's Office of Foreign Assets Control (OFAC) added Open Joint Stock Company Rosneft Oil Company ("Rosneft") and Lukoil OAO ("Lukoil") — together with dozens of named Russia-based subsidiaries — to the Specially Designated Nationals (SDN) List under Executive Order 14024 for "operating or having operated in the energy sector of the Russian Federation economy." It is the first US designation of Russia's two largest integrated oil majors since the 2022 invasion-era sanctions architecture began. Under OFAC's 50% Rule, the blocking extends automatically to all entities owned 50% or more, directly or indirectly, by Rosneft or Lukoil — capturing a sprawling global subsidiary network including Lukoil retail/refining assets in Belgium, Netherlands, Bulgaria, Romania, Italy, Finland, the West Qurna-2 upstream stake in Iraq, and Lukoil Americas. Rosneft and Lukoil together account for roughly half of Russian crude exports (~5 mb/d combined production) and Lukoil holds a ~9% European retail-fuel market share. OFAC simultaneously issued General License 124 (Caspian Pipeline Consortium / Tengizchevroil / Karachaganak Kazakhstan-pipeline carve-out, no expiry), General License 125 (Lukoil retail service stations outside Russia, wind-down to November 21, 2025), General License 126 (general wind-down to November 21, 2025) and General License 127 (debt/equity divestment and derivatives wind-down to November 21, 2025). GL 131 (issued November 14, 2025) opened a divestment window for Lukoil International GmbH; subsequent GL 134/134A/134B extended cargo-offload authorisations through April–May 2026. The action was coordinated same-day with UK OFSI Rosneft/Lukoil designations and the EU's 19th Russia sanctions package adopted October 23, 2025 — the first major US-led Russia-energy escalation under the second Trump administration.
On 9 October 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated more than 50 individuals, entities and vessels for facilitating Iranian crude oil, petroleum-product and liquefied petroleum gas (LPG) exports, in a coordinated action with the State Department. The network included 33 vessels transporting Iranian crude and LPG, shipping entities registered in Panama, the Marshall Islands, Ukraine and Liberia, an Iranian petrochemical producer, four Turkish petrochemical trading entities, five Chinese entities importing/refining/storing Iranian petroleum (including a China-based petrochemical-terminal operator, Jiangyin Foreversun Chemical Logistics Co., Ltd.), three Singapore-based logistics entities, and 27 entities based in Hong Kong, the UAE and India engaged in trading and shipping. The action was taken pursuant to the National Security Presidential Memorandum 2 (NSPM-2) maximum-pressure campaign against Iran and blocks all US property/interests of the designated parties, exposing non-US counterparties to secondary-sanctions risk.
Russia's government imposed a temporary ban on exports of diesel fuel, marine (bunker) fuel and other gas oils (EAEU HS codes 2710 19 421 0 - 2710 19 429 0), including volumes purchased on exchange trading, effective 1 October 2025. The measure was framed as a domestic fuel-market stabilisation tool and initially exempted direct refinery producers from the ban. Russia is one of the world's largest diesel/gasoil exporters, so a full-coverage export halt on these grades has global gasoil-market significance, not just a regional effect. The ban has since been extended and tightened four times through mid-2026 (see amendments).
On 11 September 2025, the US Treasury's Office of Foreign Assets Control designated 32 individuals and entities and identified four vessels in what Treasury described as its broadest sanctions action to date against Iran-aligned Ansarallah (Houthi) support networks. The designated network — companies, owners, and operatives located in Yemen, China, the UAE, and the Marshall Islands — is accused of running oil and commodity smuggling through Houthi-controlled Yemeni ports, laundering the proceeds, and using them to finance a global weapons procurement supply chain of front companies and shipping facilitators. The action was taken pursuant to Executive Order 13224 (as amended) and builds on nine prior 2024-2025 OFAC actions against Houthi leaders, smugglers, financiers, and suppliers.
On 2 September 2025 Mexico's Finance Ministry (SHCP) launched a capitalisation and refinancing strategy for state oil company Petróleos Mexicanos (Pemex), opening a USD 12 billion bond repurchase offer (of which USD 9.9 billion targeted 2026-2029 maturities). Between 15-16 September, SHCP placed a new basket of euro- and dollar-denominated bonds totalling USD 13.8 billion equivalent (EUR 5 billion across 4/8/12-year tranches at 3.500%, 4.500% and 5.125% coupons; USD 8 billion across 5/7/10-year tranches at 4.750%, 5.375% and 5.625% coupons), taking the combined operation to roughly USD 21.8 billion. SHCP stated the goal was to strengthen Pemex's capitalisation levels, reduce its financial debt balance, manage supplier obligations, fund investment projects, and improve its debt-maturity profile. The operation is part of the government's 2025-2035 Pemex strategic (rescue) plan and preceded credit-rating upgrades from Fitch (B+ to BB) and Moody's (B3 to B1, stable outlook).
On 30 July 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated more than 50 individuals and entities and identified more than 50 vessels belonging to the shipping empire of Mohammad Hossein Shamkhani, son of Ali Shamkhani, a top political adviser to Iran's Supreme Leader. Treasury described the action — over 115 sanctions in total — as its largest Iran-related action since 2018. The network launders billions of dollars from sales of Iranian and Russian crude oil and petroleum products (mostly to buyers in China) through vessels and front companies registered across the UAE, Hong Kong, India, Cyprus, Panama, Romania, China, Liberia, the Marshall Islands and Seychelles. Concurrently, the State Department designated 20 entities and identified 10 vessels under E.O. 13846 and E.O. 13902 for trading and transporting Iranian petroleum and petrochemical products.
Law No. 7554 (Bazı Kanunlarda Değişiklik Yapılmasına Dair Kanun), adopted by the Grand National Assembly on 19 July 2025 and published in Resmî Gazete No. 32965 on 24 July 2025, amends Mining Law No. 3213 to introduce the first statutory definition of "stratejik ve kritik madenler" (strategic and critical minerals) in Turkish law. The law creates a Board override mechanism chaired by a Vice-Presidential delegate that can compel permit issuance for strategic/critical mineral projects when lower authorities have refused, designates MAPEG as the licensing authority within one month of a favourable Board decision, and mandates EIA Positive Decisions for all in-scope projects (eliminating the prior "EIA Not Required" option). Transitional provisions preserve old-regime rules for existing licence-holders until 1 January 2026.
On 3 July 2025, the US Treasury's Office of Foreign Assets Control designated a network of UAE- and UK-based companies controlled by Iraqi-British businessman Salim Ahmed Said that has smuggled Iranian oil disguised as Iraqi crude since at least 2020, plus five additional shadow-fleet vessel owners based in Seychelles, the Marshall Islands, and the British Virgin Islands. The action, taken pursuant to E.O. 13902 (Iran petroleum sector) and E.O. 13224 (counterterrorism), also identifies several tankers as blocked property and marks the eighth round of sanctions under National Security Presidential Memorandum 2's Iran maximum-pressure campaign. Concurrently, the State Department designated six additional entities and four vessels under E.O. 13846.
On 20 June 2025, the US Treasury's Office of Foreign Assets Control designated four individuals, twelve entities, and two vessels in what Treasury called its single largest action to date against Iran-backed Ansarallah (the Houthis), pursuant to Executive Order 13224 as amended. The designated network — Sana'a- and Hudaydah-based oil-trading front companies (including Black Diamond Petroleum Derivatives, Star Plus Yemen, Tamco Establishment, Royal Plus Shipping, and Abbot Trading) and their Houthi operator-owners — facilitates black-market oil and oil-derivative sales that fund Houthi militant operations, while shipping firms Best Way Tanker Corp, Ocean Voyage LLC, and Atlantis M. Shipping Co were designated for discharging over 120,000 combined metric tons of gasoline and LPG at the Houthi-controlled Ras Isa port via the vessels Valente and Atlantis MZ after the April 2025 expiration of Counter Terrorism General License 25A. The action builds on OFAC's June 2024–April 2025 cadence of designations against Houthi leaders, weapons-procurement operatives, and suppliers.
On 8 May 2025, the US Treasury's Office of Foreign Assets Control designated China-based "teapot" refinery Hebei Xinhai Chemical Group Co., Ltd. and its Singapore-based broker subsidiary Xing AO Energy PTE. LTD., three firms tied to a Dongying Port (Shandong) terminal that has received Iranian crude from shadow-fleet tankers, and six Hong Kong-, UK-, and Marshall Islands-owned shadow-fleet vessels (STAR TWINKLE 6, LAMD, SKADI, BIG MAG, IMPALAS, THANE) plus their owning shipping companies and two vessel captains. It is OFAC's third action against an Iranian-oil teapot refinery and its first targeting Shandong port terminal operators, taken under E.O. 13902 (Iran petroleum/ petrochemical sector) and E.O. 13846 (NIOC support) as part of the administration's NSPM-2 maximum-pressure campaign.
Pakistan launched the National Minerals Harmonisation Framework 2025 and the Mines & Minerals Act 2025 at the Pakistan Minerals Investment Forum (Islamabad, 8–9 April 2025), consolidating six regulatory frameworks, eight legislative instruments, and 36 rule sets into a unified federal-provincial licensing system. The framework — convened by the SIFC and Deputy PM Ishaq Dar — establishes a two-tier licensing structure (large-scale: PKR 500M+; small-scale: PKR 25M–500M), mandatory appellate tribunal, and a "Mines and Minerals Force" to counter illegal mining in Sindh and Balochistan. Fiscal-incentive reforms aim to raise investor IRR from 14.5% to approximately 18%, underpinned by Reko Diq as the flagship precedent for future large-scale foreign-capital mineral projects.
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.
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.
On January 10, 2025, the US Treasury's Office of Foreign Assets Control (OFAC), acting jointly with the Department of State, designated PJSC Gazprom Neft and PJSC Surgutneftegas as Specially Designated Nationals (SDNs) under Executive Orders 13662 and 14024, alongside more than 180 oil-carrying vessels (the bulk of Russia's "shadow fleet"), dozens of opaque oil traders, two major Russia-based oilfield service providers, marine insurance companies, and senior Russian energy-sector officials. The package included a new EO 14024 sectoral determination authorizing future designations against any person operating in the Russian energy sector, plus a new EO 14071 determination prohibiting the provision of US petroleum services (extraction, drilling, production support) to persons located in the Russian Federation, effective 12:01 a.m. EST on February 27, 2025. OFAC simultaneously issued General Licenses 117 (wind-down of transactions with the newly blocked entities) and 118 (debt/equity/derivatives wind-down), both expiring February 27, 2025. The action was the largest single Russia energy-sector designation since the 2022 invasion regime began and was coordinated with parallel UK OFSI shadow-fleet designations issued the same week. The action was finalized in the closing days of the Biden administration as a deliberate tightening of the oil-revenue and shadow-fleet vectors before the January 20 transition. Subsequent enforcement and any rollback decisions fell to the incoming Trump administration.
On 11 October 2024, the Secretary of the Treasury — acting in consultation with the Secretary of State and pursuant to section 1(a)(i) of Executive Order 13902 — determined that the petroleum and petrochemical sectors of the Iranian economy are sectors of strategic concern, exposing non-US persons that operate in or knowingly facilitate significant transactions with those sectors to secondary sanctions and SDN-listing risk. The determination was issued in response to Iran's 1 October 2024 ballistic- missile attack on Israeli targets and was formally published in the Federal Register on 19 November 2024 (FR Doc 2024-26800). Concurrent with the determination, OFAC designated an international network — including Sepehr Energy Jahan Nama Pars — that had shipped millions of barrels of Iranian crude on behalf of Iran's Armed Forces General Staff to the People's Republic of China.
On 2 August 2024, President Luiz Inácio Lula da Silva sanctioned Lei nº 14.948/2024 (with partial veto, Mensagem nº 741) at a ceremony in the Pecém Industrial-Port Complex in Ceará, following Senate and Chamber approval of PL 2308/2023; the law was published in the Diário Oficial da União on 5 August 2024. The statute establishes Brazil's first comprehensive legal framework for low-carbon hydrogen: it (i) creates the National Low-Carbon Hydrogen Policy (PNH2BC) under the National Energy Policy umbrella, (ii) sets a statutory definition of "low-carbon hydrogen" as fuel/industrial input with lifecycle GHG intensity ≤ 7 kg CO₂e/kg H₂, (iii) institutes the Brazilian Hydrogen Certification System (SBCH2) for origin and emissions accreditation, (iv) creates the Special Incentive Regime for Low-Carbon Hydrogen Production (Rehidro), suspending PIS/Pasep and Cofins for five years on capital-goods, raw-materials and services purchases by qualified producers, and (v) authorises the Programa de Desenvolvimento do Hidrogênio de Baixa Emissão de Carbono (PHBC) — a tax-credit envelope capped at BRL 18.3 bn between 2028 and 2032 (subsequently regulated by Lei nº 14.990/2024 sanctioned 30 September 2024). ANP gains regulatory authority over hydrogen transportation, storage and import/export licensing, while the law amends Leis nºs 9.427/1996 (ANEEL) and 9.478/1997 (Petroleum Law) to integrate hydrogen into the energy-policy and electricity-regulation framework. Industry reporting at sanction cited >USD 30 bn in announced project pipeline, concentrated in Northeast renewable-rich states (Ceará, Bahia, Pernambuco, Rio Grande do Norte) leveraging Pecém, Suape and Açu as hydrogen-derivative export terminals.
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.
On 31 January 2024 Switzerland's Federal Council decided to align with the EU's 12th sanctions package (adopted 18 December 2023) by amending the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), entering into force the same day at 18:00. The update extends Switzerland's Russia-sanctions perimeter to match the EU's additions — including the Russian diamond, steel and other import-revenue restrictions — and adds a new financial-sector prohibition barring Russian nationals and Russia-resident individuals from controlling Swiss crypto-asset service providers, aimed at closing sanctions-circumvention and enforcement gaps.
The Council of the EU adopted Council Regulation (EU) 2023/2878 of 18 December 2023, the EU's 12th sanctions package against Russia, entering into force 19 December 2023. The package introduces a direct EU import ban on Russian non-industrial natural and synthetic diamonds and diamond jewellery effective 1 January 2024, followed by a phased indirect ban on Russian diamonds processed in third countries (from 1 March 2024, complete by 1 September 2024), developed as part of a G7-coordinated diamond restriction. The package also extends import bans on steel and other products generating significant revenue for Russia, and adds further trade and economic restrictions.
Guyana's National Assembly passed the Petroleum Activities Act, No. 17 of 2023 (PAA), which received presidential assent and was published in the Extraordinary Official Gazette on 16 August 2023, replacing the Petroleum (Exploration and Production) Act 1986 (Chapter 65:10) in its entirety. The PAA establishes a modern upstream regulatory architecture including a 10% gross royalty, a 65% cost-recovery ceiling under new Production Sharing Contracts (PSCs), a 10% corporate income tax on petroleum activities, and an updated licensing, local-content, decommissioning, and environment-compliance framework. Existing agreements — including the 2016 Stabroek Block PSA (ExxonMobil/Hess/CNOOC consortium, 2% royalty, 75% cost-recovery ceiling) — are grandfathered under their original terms; the PAA governs all new licensing rounds and agreements.
On 6 October 2022 the Council of the European Union adopted Council Regulation (EU) 2022/1904, amending Regulation (EU) No 833/2014, as the EU's eighth package of restrictive measures against Russia. It entered into force 7 October 2022. The regulation's headline measure creates the legal basis for an oil price-cap mechanism: a ban on maritime transport to third countries of Russian-origin crude oil and petroleum products, becoming operational once the Council sets an actual cap level by a separate decision (the G7/EU $60/bbl cap followed on 3 December 2022). The package also expands import bans on steel products (phased through 2024), firearms and ammunition, wood pulp and paper, and certain chemicals, cosmetics and jewellery materials; extends export bans on aviation-sector goods; bans the provision of architectural, engineering, IT-consultancy and legal advisory services to the Russian government and Russian companies; and imposes restrictions on Russian-flagged vessels at the Russian Maritime Register.
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.
On 3 June 2022 the Council of the European Union adopted Regulation (EU) 2022/879, the sixth package of sanctions against Russia over the invasion of Ukraine, further amending Regulation (EU) No 833/2014. It bans the seaborne import of Russian crude oil and refined petroleum products, covering roughly two-thirds of EU oil imports from Russia at adoption (pipeline deliveries via Druzhba were temporarily exempted). It removes Sberbank, Credit Bank of Moscow and Russian Agricultural Bank from SWIFT (Annex XIV), bans EU operators from providing accounting, auditing, bookkeeping, tax consulting, business/management consulting and public-relations services to persons in Russia (new Article 5n), and adds three more Russian broadcasters to the EU broadcasting-suspension list (Annex XV). It entered into force on 4 June 2022, the day after publication in the Official Journal.
Russian Government Resolution No. 506 of 29 March 2022, signed by Prime Minister Mikhail Mishustin and effective 30 March 2022, authorises the Ministry of Industry and Trade (Minpromtorg) to designate categories of goods exempt from articles 1252(4), 1359(6) and 1487 of the Russian Civil Code on national/regional exhaustion of trademark and other intellectual- property rights. Followed by Minpromtorg Order No. 1532 of 19 April 2022 publishing an initial list of 55 goods categories and named brands — including pharmaceuticals, electronics, automotive parts, mineral fuels, industrial chemicals, paper, textiles, base metals, and consumer goods — for which parallel (grey-market) imports without IP-holder consent are legalised. Designed as a sanctions-circumvention and supply-substitution instrument after the Western corporate exodus of March 2022; extended annually and most recently re-authorised through 31 December 2026.
Guyana's National Assembly passed Act No. 18 of 2021 on 29 December 2021; it received presidential assent and was published in the Extraordinary Official Gazette on 31 December 2021. The Act establishes mandatory local-content obligations for all operators, contractors, and subcontractors engaged in petroleum operations in Guyana, defining a "Guyanese company" (≥51% Guyanese-owned, ≥75% Guyanese senior management, ≥90% other staff) and reserving 40 First Schedule categories of goods and services exclusively for Guyanese nationals and companies. All entities in the petroleum value chain must register with the Local Content Secretariat and submit annual local-content plans and compliance reports to the Minister of Natural Resources.
Angola's President João Lourenço signed Decreto Presidencial n.º 271/20 on 20 October 2020, replacing Order n.º 127/03 of 2003 and establishing the Regime Jurídico do Conteúdo Local do Sector dos Petróleos (RJCLSP). The decree divides petroleum-sector contracting into three regimes — exclusivity (reserved for Angolan nationals and companies), preference (Angolan-majority bidders take priority), and open competition with mandatory local-content scoring — covering all goods and services contracts entered into by concessionaires and their full subcontracting chains. The Ministério dos Recursos Minerais, Petróleo e Gás (MIREMPET) supervises compliance, with non-inclusion of mandatory local-content clauses penalised at USD 50,000–200,000 per infraction and escalating to contract cancellation for repeat offenders. The RJCLSP applies to all IOCs operating Angolan offshore blocks, including TotalEnergies (Block 17), ExxonMobil (Block 15), Chevron (Blocks 0, 14, 14K), BP (Block 31), Eni (Blocks 2, 14, 15/06), and Equinor, as well as their oilfield-services subcontractor chains.
Senegal's National Assembly adopted Loi n° 2019-04 on 24 January 2019 and President Macky Sall promulgated it on 1 February 2019, establishing the foundational legal framework for maximising Senegalese participation across the entire hydrocarbon value chain — from exploration through decommissioning. The law creates three activity-classification regimes (exclusif, mixte, non-exclusif), mandates priority employment of Senegalese workers, and creates two implementing bodies: the Comité National de Suivi du Contenu Local (CNSCL, via Décret 2020-2046) and the Fonds d'appui au développement du contenu local (FADCL, via Décret 2020-2048). It underpins all petroleum contracts under which Petrosen, Woodside (Sangomar, first oil June 2024), bp/Kosmos (GTA Tortue Ahmeyim, first gas December 2024), and future Yakaar-Teranga development licenses operate.
On 27 December 2017 President Nursultan Nazarbayev signed Code No. 125-VI ZRK "On Subsoil and Subsoil Use," a wholesale recodification replacing the 2010 Subsoil Use Law that entered into force on 29 June 2018 (with certain provisions deferred to 1 January 2019). The Code establishes the licensing architecture for all mineral extraction in Kazakhstan — the world's leading uranium producer (~40% of global U₃O₈ output, ~22,000 tU/yr) and a top-11 oil exporter (~1.8 mbpd) — covering solid minerals, hydrocarbons, and uranium under a single codified framework. For solid minerals the Code introduces a liberalised "first-come first-served" auction-free licence model for non-strategic deposits and a state-tender model for strategic deposits, alongside subsoil-use rights transfer and pledge provisions governing all M&A in the sector. For uranium the Code codifies the National Atomic Company Kazatomprom's statutory role as state operator over all uranium blocks, with government priority pre-emption rights and mandatory Kazatomprom participation in all production licences. For hydrocarbons the Code establishes the concession and production-sharing framework governing the pre-salt Caspian mega-projects (Tengiz, Karachaganak, Kashagan) and the model contract architecture for petroleum products. Horizontal obligations — local Kazakh-content procurement floors, social-package requirements, and environmental-restoration mine-closure security — apply across all subsoil-use categories. Structurally this Code is the parent statute for every subsequently filed KZ action: the 2023-12-28 REE Comprehensive Plan and the 2025-12-26 Kazatomprom uranium-priority amendments both operate under delegated authority created by this Code.
The Mineral and Petroleum Resources Development Act, Act 28 of 2002, assented to by President Thabo Mbeki on 3 October 2002 and commenced on 1 May 2004 (Proclamation R.25 of 2004), is the foundational post-apartheid statute governing all mineral and petroleum resources in South Africa. The Act vests custodianship of all SA mineral and petroleum resources in the State for the benefit of all South Africans, abolishes the old-order private-ownership system of mineral rights, and establishes the Mineral and Petroleum Titles Registration Office (MPTRO). It creates the licensing regime for prospecting, mining, exploration, and production rights as limited real rights tied to land under Chapters 3–6, and embeds the Mining Charter BEE-ownership transformation framework via Section 100(2) — subsequently litigated in Chamber of Mines v Minister of Mineral Resources [2018] (SCA). The MPRDA is the parent authority for all subsequent SA mining-sector regulation including the 2008 Royalty Act, the 2018 Mining Charter III, and the 2025 Mineral Resources Development Bill currently pending before Parliament.
The Trade Expansion Act of 1962 (Pub. L. 87-794, 76 Stat. 872), signed into law by President Kennedy on 11 October 1962 and codified at 19 U.S.C. §§ 1801–1991, is the foundational US statute granting the executive branch broad authority to negotiate tariff reductions and, critically via Section 232 (19 U.S.C. § 1862), to adjust imports of any article found by the Secretary of Commerce to threaten to impair national security. Section 232 empowers the President — on receipt of a Commerce Department affirmative national-security finding — to impose tariffs, quantitative restrictions, or other import-adjustment measures without congressional approval or WTO-required safeguard procedures. From 1962 to the Trump Administration's 2018–2026 wave of Section 232 Proclamations, the authority was invoked primarily for petroleum and machine-tool imports; since 2018 it has become the legal vehicle for national-security tariffs on steel, aluminum, automobiles, copper, timber, critical minerals, semiconductors, and pharmaceuticals, with 19+ IPTM-filed implementing instruments citing Pub. L. 87-794 / 19 U.S.C. § 1862 as their statutory parent.