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

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.

OFAC issued two determinations under Executive Orders 14068 and 14071 banning the import into the United States of Russian-origin aluminum, copper, and nickel produced on or after April 13, 2024, and separately prohibiting the provision of warranting/deliverable services for these metals on global exchanges (LME, CME) and their use to settle over-the-counter derivative contracts. Metal produced before the effective date is grandfathered. The action was coordinated with the United Kingdom, which imposed parallel exchange-listing prohibitions the same day, following G7 statements on reducing Russia's metals revenue.

Poland's Minister of Development and Technology, Waldemar Buda, established a temporary compulsory administrator (tymczasowy zarządca przymusowy) over the Grupa Azoty S.A. shares held by sanctioned Russian oligarch Vyacheslav Kantor through three holding vehicles — Norica Holding S.à r.l. (Luxembourg), Opansa Enterprises Limited and Rainbee Holdings Limited (both Cyprus) — which together controlled 19.82% of the state-linked fertiliser and chemicals group, worth over PLN 0.5bn. The ministry cited Kantor's inclusion on Poland's sanctions list and the protection of the country's economic and energy security, and stated its intent to find a buyer for the stake and compensate Kantor. The Provincial Administrative Court in Warsaw (WSA) later overturned the decision establishing the administration; the ministry did not appeal, and the ruling became final around 30 July 2024, ending the administrator's mandate — though the underlying EU/Polish sanctions on Kantor continue to freeze his ability to exercise any rights attached to the shares.