Industrial Policy & Trade Monitor· 2665 actions· ✨ 90 recent

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.

Statutory Instrument 213 of 2022, gazetted 16 December 2022 by Zimbabwe's Ministry of Mines and Mining Development, banned the export of lithium-bearing ores and unbeneficiated lithium except with the written permission of the Minister. The stated rationale was to force in-country beneficiation and curb revenue lost to illegal mining and smuggling of raw ore. Refined/beneficiated lithium concentrate exports were not covered and continued under the pre-existing regime. This is the foundational instrument that Zimbabwe's later lithium-export architecture (SI 57 of 2023, the February 2026 all-raw-mineral suspension) built on top of.

Indonesia banned the export of raw bauxite ore (including washed bauxite) effective 10 June 2023, extending the "hilirisasi" (downstream-isation) doctrine that previously prohibited nickel-ore exports (effective 1 January 2020) to the country's second-largest mineral export. The ban is implemented through the existing Mining Law framework (UU 3/2020 amending UU 4/2009) and operationalised via Ministry of Trade Regulation Permendag 18/2022 on Provisions for Mining-Product Exports. President Joko Widodo formally announced the bauxite-export-ban schedule on 21 December 2022, citing forecast revenue uplift from IDR 21 trillion to IDR 62 trillion (~USD 1.35bn → ~USD 3.9bn) once domestic alumina/ aluminium refining ramps.

The Bureau of Industry and Security added 36 entities — 35 in China, 1 in Japan — to the Entity List under a presumption of denial for all EAR-controlled items, effective December 16, 2022. The most consequential additions are Yangtze Memory Technologies (YMTC, simultaneously removed from the Unverified List), eight Cambricon AI-chip subsidiaries, and Shanghai Micro Electronics Equipment (SMEE), China's sole domestic lithography producer. Three existing entries were revised: CETC 13 and two affiliates gained a Footnote 3 Russian-military-end-user designation, bringing them under the Russia/Belarus Foreign Direct Product rule with a blanket denial policy.

On 16 December 2022 the Council of the European Union adopted Council Regulation (EU) 2022/2474, the 9th package of restrictive measures against Russia, amending Regulation (EU) 833/2014. It entered into force on publication the following day (17 December 2022). The package extends the prohibition on new EU investment from the Russian energy sector to the Russian mining and quarrying sector, bans exports of aircraft and drone engines and their parts to Russia (and to any third country that could re-supply drones to Russia), adds 168 entities to the sectoral export- control annex covering chemicals, nerve agents, night-vision and radio- navigation equipment, electronics and IT components, and prohibits EU advertising, market-research, product-testing and technical-inspection services to Russia. A parallel Council Decision/Implementing Regulation designated a further 141 individuals and 49 entities to the EU asset-freeze and travel-ban list.

Directive (EU) 2022/2557 of the European Parliament and of the Council of 14 December 2022 on the resilience of critical entities, published OJ L 333, 27 December 2022, entered into force 16 January 2023, with Member State transposition deadline 17 October 2024 (rules applicable from 18 October 2024). The CER Directive repeals Council Directive 2008/114/EC on European Critical Infrastructures, extending the scope from two sectors (energy, transport) to eleven essential-service sectors: energy, transport, banking, financial market infrastructures, health, drinking water, wastewater, digital infrastructure, public administration, space, and food. Member States must adopt national resilience strategies, conduct risk assessments at least every four years, identify "critical entities" providing essential services whose disruption would have significant cross-border impacts, and ensure those entities implement technical, security, and organisational resilience measures, business-continuity plans, incident-reporting obligations, and personnel-security background checks. The CER Directive is the physical and hybrid resilience twin to the NIS2 Directive (2022/2555) — the two instruments form the binding EU critical-infrastructure-protection architecture replacing the 2008/114/EC regime.

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.

Directive (EU) 2022/2555 of the European Parliament and of the Council of 14 December 2022 on measures for a high common level of cybersecurity across the Union (NIS 2 Directive), published OJ L 333, 27 December 2022, entered into force 16 January 2023. NIS2 repeals and substantially expands the 2016 NIS1 Directive (2016/1148), extending the scope from ~7 sectors to 18 enumerated essential and important sectors, imposing binding cybersecurity risk- management and incident-reporting obligations on covered entities, introducing board-level management accountability, and mandating Member State transposition by 17 October 2024. NIS2 is the structural EU statutory anchor for national cybersecurity frameworks across the bloc, operating alongside DORA (Reg 2022/2554) for financial-sector digital resilience and CRA (Reg 2024/2847) for product cybersecurity.

Council Directive (EU) 2022/2523, adopted 14 December 2022 and published in OJ L 328 on 22 December 2022, transposes the OECD/G20 Inclusive Framework Pillar Two model rules into binding EU law. It requires all 27 Member States to impose a minimum 15% effective tax rate (ETR) on the jurisdictional income of MNE groups with consolidated annual revenue ≥ EUR 750 million via three interlocking charges: an Income Inclusion Rule (IIR) for fiscal years beginning on or after 31 December 2023, an Undertaxed Profits Rule (UTPR) backstop from 31 December 2024, and an optional Qualified Domestic Minimum Top-up Tax (QDMTT). The directive is the largest international-tax instrument in EU history and the operative legal anchor for the cross-border Pillar Two architecture inside the single market, structurally rebalancing FDI location decisions for an estimated 12,000+ in-scope MNE groups globally.

The Bureau of Industry and Security added 24 entities across 26 entries to the Entity List, effective December 8, 2022, covering Latvia, Pakistan, Russia, Singapore, Switzerland, and the United Arab Emirates. Three distinct enforcement clusters are addressed: Russian defense-electronics firms and their foreign affiliates supporting Russia's military-industrial base post-Ukraine invasion; Singapore-based front companies that supplied controlled items to PASNA, an Iran-based Specially Designated National; and Pakistani and Emirati entities engaged in unsafeguarded nuclear activities and ballistic-missile proliferation. One entity (Safe Technical Supply Co., LLC) was simultaneously removed from three entries covering Oman, Saudi Arabia, and the UAE.

OFAC issued a determination under Executive Order 14071 (Russian Harmful Foreign Activities Sanctions) effective December 5, 2022, establishing a $60/barrel price cap on Russian seaborne crude oil. The measure prohibits US persons from providing six categories of covered services — trading/commodities brokering, financing, shipping, insurance (including reinsurance and P&I), flagging, and customs brokering — for the maritime transport of Russian crude oil unless the oil is purchased at or below $60/bbl. The determination was coordinated with the EU, G7 nations, and Australia as a unified coalition instrument designed to reduce Russian oil revenues while keeping global energy markets supplied. Three general licenses (GL 55, 56, 57) carved out limited exemptions for Japan's Sakhalin-2 imports, certain EU landlocked states, and vessel emergencies.

Belgium's first horizontal foreign-direct-investment screening regime, established by a Cooperation Agreement signed on 30 November 2022 between the Federal State and the Flemish, Walloon, Brussels-Capital and German-Community governments, and in force from 1 July 2023. The agreement creates a centralised Interfederal Screening Commission (ISC), chaired by the FPS Economy, to receive and process mandatory ex-ante notifications of foreign acquisitions of 10%, 25% or higher voting-rights / control thresholds (sector-dependent) in Belgian undertakings active in eleven strategic sectors. ISC decisions are binding; sanctions for failure to notify or for non-compliance with conditions imposed include unwinding of the transaction and administrative fines.

Act No. 497/2022 Coll. on the Screening of Foreign Investments and on amendments to certain acts, adopted by the National Council of the Slovak Republic on 29 November 2022 and promulgated in the Zbierka zákonov on 23 December 2022, established Slovakia's first horizontal ex-ante foreign-direct-investment screening regime. The Act took effect on 1 March 2023, transposing EU Regulation 2019/452 into Slovak law and replacing the prior sector-specific approach under Act No. 45 on critical infrastructure. Screening is administered by the Ministry of the Economy of the Slovak Republic across three procedures (mandatory, voluntary, and ex officio) and covers transactions in defence, dual-use, critical infrastructure, critical raw materials, biotechnology, AI, semiconductors and other emerging technologies. The Ministry can prohibit, condition or unwind non-compliant transactions and impose administrative penalties.

Angola's Ministry of Transport formalised a 30-year concession to Lobito Atlantic Railway (LAR — Trafigura 49.5% / Mota-Engil 49.5% / Vecturis S.A. 1%) for the operation, management and maintenance of the Lobito Corridor — comprising the 1,300 km Benguela Railway from the Port of Lobito to Luau (Angola-DRC border) and the Lobito port mineral terminal. The international tender was won on 4 November 2022; the concession contract was signed on 4 July 2023 at a ceremony attended by the Presidents of Angola, the DRC and Zambia. LAR commenced operations in January 2024. The concession is paired with the trilateral Lobito Corridor Transit Transport Facilitation Agency Agreement (LCTTFA), signed at Lobito Port on 27 January 2023 by the Transport ministers of Angola, the DRC and Zambia, which establishes the cross-border customs/transit framework for the corridor.

On 28 October 2022, Canada's Minister of Innovation, Science and Industry (François-Philippe Champagne) and Minister of Natural Resources (Jonathan Wilkinson) issued a new policy on how the Investment Canada Act applies to investments by foreign state-owned enterprises (SOEs) in Canada's critical minerals sector. Acquisitions of control of a Canadian critical-minerals business by a foreign SOE will now only be approved "on an exceptional basis," and any SOE participation in a Canadian business operating in a critical-minerals sector or supply chain will automatically trigger national-security scrutiny. The policy applies to the 31 minerals on Canada's Critical Minerals List (established 11 March 2021) and preceded, by five days, the 2 November 2022 orders forcing three Chinese-controlled companies to divest lithium-junior stakes.

Regulation (EU) 2022/2065 on a Single Market For Digital Services (Digital Services Act, DSA) was adopted by the European Parliament and Council on 19 October 2022, published in OJ L 277 on 27 October 2022, entered into force on 16 November 2022, and applied in full from 17 February 2024 (with VLOP/VLOSE obligations applying from 25 August 2023 following the Commission's initial designation letters of February 2023). The DSA establishes a graduated intermediary-liability and platform-safety framework covering all online intermediaries serving EU users, with the heaviest obligations falling on designated Very Large Online Platforms (VLOPs, ≥45m monthly active EU users) and Very Large Online Search Engines (VLOSEs): systemic-risk assessments, annual independent audits, vetted-researcher data access, recommender-system transparency, online-advertising transparency, and crisis-response cooperation mechanisms under Commission coordination. The European Commission holds exclusive enforcement authority over VLOPs and VLOSEs, with fines up to 6% of global turnover. The DSA is the structural twin-pillar to the Digital Markets Act (Reg (EU) 2022/1925): the DMA governs ex-ante competition obligations on designated gatekeepers; the DSA governs ex-post intermediary-liability, content-moderation, and platform-safety obligations across all online intermediaries.

On 18 October 2022, Crown Prince Mohammed bin Salman launched Saudi Arabia's National Industrial Strategy (NIS) under the Vision 2030 umbrella, with delivery led by the Ministry of Industry and Mineral Resources (MIM). The strategy prioritises 118 segments within 12 industrial sub-sectors (including downstream chemicals, automotive, aerospace, machinery, and metals), identifies more than 800 investment opportunities estimated at ~USD 266bn, and sets binding 2030/2035 targets: triple manufacturing GDP by 2030, raise industrial exports to SAR 557bn (~USD 148bn), bring cumulative additional investment to SAR 1.3 trillion, and grow factories from ~10,000 to ~36,000 by 2035. NIS sits alongside the National Industrial Development and Logistics Program (NIDLP, 2019) and the Public Investment Fund's strategic-sector mandates as the third leg of the Kingdom's non-oil-economy build-out.

The US Bureau of Industry and Security imposed broad new controls on the export of advanced computing chips, chipmaking equipment, and US-person services supporting Chinese semiconductor fabrication. The October 7 2022 rule blocked supply of GPUs above set performance thresholds (initially 600 GB/s interconnect / 4800 TOPS) to China and added end-use restrictions on manufacturing tools used in advanced (≤14/16 nm logic, ≤18 nm DRAM, ≤128-layer NAND) facilities, with a foreign direct product rule extending coverage globally.

The Bureau of Industry and Security (BIS) added 31 Chinese entities — including Yangtze Memory Technologies Co., Ltd. (YMTC), China's largest NAND flash manufacturer — to the Unverified List (UVL), suspending license exceptions and requiring end-user statements for all EAR-controlled items destined to these parties. BIS simultaneously removed nine Chinese entities previously on the UVL after successfully completing end-use checks. The rule also established a new 60-day UVL-to-Entity-List escalation clock and clarified that sustained host-government obstruction of end-use checks constitutes independent grounds for Entity List designation — a structural enforcement change aimed at closing China's pattern of blocking BIS post-shipment verification visits.

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 Bureau of Industry and Security added 57 entities under 57 entries to the Entity List, effective September 30, 2022, in direct response to Russia's ongoing invasion of Ukraine and its illegal annexation of Ukrainian regions. Of the 57 entities, 56 are listed under Russia and one (Subsidiary Sevastopol Naval Plant of Zvezdochka Shipyard) under the Crimea Region of Ukraine. The additions span aviation repair and overhaul facilities, aerospace R&D institutes, naval propulsion, ballistic-missile producers, advanced-materials and quantum science institutes, and the federal metrology agency; 50 of the 57 receive footnote 3 designations as Russian military end users, subjecting them to the Russia/Belarus-Military End User Foreign Direct Product Rule. All are added with a license review policy of denial for all EAR-subject items except food and medicine designated EAR99.

The Bureau of Industry and Security expanded EAR sanctions against Russia and Belarus effective 15 September 2022, adding new export-control categories covering quantum computing equipment and related technology (new licensing requirements under a near-total policy of denial), discrete chemicals and biologics including fentanyl precursors and CBW-related production equipment (new Supplement No. 6 to Part 746), and 57 EAR99 industrial items added to the industry-sector sanctions list (Supplement No. 4). Six entities were concurrently designated as Russian Military End Users (MEU), and MEU/MIEU licensing restrictions were extended worldwide (previously limited to six countries). The rule also extended the Foreign Direct Product Rule to additional categories of foreign-made items.

Regulation (EU) 2022/1925 of the European Parliament and of the Council of 14 September 2022 on contestable and fair markets in the digital sector (Digital Markets Act, DMA) was published in OJ L 265 on 12 October 2022, entered into force on 1 November 2022, and applied for the most part from 2 May 2023. The DMA establishes an ex-ante competition framework imposing binding obligations and prohibitions on designated "gatekeepers" operating Core Platform Services (CPS) in the EU — covering search engines, social-networking services, video-sharing platforms, number-independent interpersonal communications, operating systems, web browsers, virtual assistants, cloud computing, online intermediation services, and online advertising. The European Commission designated six gatekeepers on 6 September 2023 (Alphabet, Amazon, Apple, ByteDance, Meta, Microsoft); full compliance with all obligations was required by 7 March 2024. Subsequent designations added Booking.com (May 2024) and Apple iPadOS (April 2024). The DMA functions as the EU's structural anchor for ex-ante digital competition regulation, closing the enforcement gap left by ex-post competition law (Articles 101–102 TFEU) where market-tipping dynamics make remedies ineffective after the fact.

The U.S. Bureau of Industry and Security (BIS) added seven Chinese entities — under seven entries — to the Entity List, effective August 24, 2022, for acquiring or attempting to acquire U.S.-origin items in support of China's military modernization efforts. The entities span China's state-owned aerospace, space-technology, electronics, and control-systems research institutes. All seven entries carry a license requirement covering all items subject to the EAR, with a presumption-of-denial review policy.

The Inflation Reduction Act (Public Law 117-169), signed by President Biden on 16 August 2022, contains the largest single package of clean-energy and clean-manufacturing subsidies in US history — Congressional Budget Office scored the energy and climate provisions at $369B over 10 years, with subsequent Treasury / academic estimates reaching $800B-$1.2T as uptake exceeded baseline. Core mechanisms include the Section 30D Clean Vehicle credit ($7,500 per qualifying EV), the Section 45X Advanced Manufacturing Production Credit (per-unit credits for domestically-produced battery cells, modules, electrodes, and critical-mineral processing), the Section 48E Clean Electricity Investment Credit, and the Section 45V Clean Hydrogen Production Credit. Critically, the law contains Foreign Entity of Concern (FEOC) provisions barring credit eligibility for vehicles or components linked to entities controlled by China, Russia, Iran, or North Korea.

Government Decree 53/2022/ND-CP, signed 15 August 2022 and effective 1 October 2022, implements Article 26 of Vietnam's 2018 Law on Cybersecurity. It mandates in-country storage of three categories of data — personal data of users in Vietnam, user-generated data, and user-relationship data — for both domestic and foreign cyberspace- service providers, with a minimum 24-month retention period. Foreign enterprises providing telecoms, data storage, domain names, e-commerce, online payments, social networks, online video games, or messaging services to users in Vietnam must establish a Vietnamese branch or representative office within 12 months of a Minister of Public Security written request. The decree closes a four-year implementation gap on the 2018 Cybersecurity Law and is the principal Vietnamese digital-trade barrier alongside Decree 13/2023/ND-CP (Personal Data Protection).

The CHIPS and Science Act (Public Law 117-167), signed into law by President Biden on 9 August 2022, appropriated $52.7 billion in direct semiconductor industry support: $39B in manufacturing incentives administered by the Commerce Department, $13.2B for R&D and workforce, and $0.5B for legacy-chip and supply-chain programs. It also created an Advanced Manufacturing Investment Credit (Section 48D) — a 25% refundable investment tax credit on qualified semiconductor manufacturing property. The law included a "guardrails" clause prohibiting recipients from expanding advanced-node capacity in countries of concern (most prominently China) for 10 years following award.

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.

The US Department of Commerce Bureau of Industry and Security (BIS) added 71 entities — 70 Russian and 1 Belarusian — to the Entity List, effective June 2, 2022, in direct response to Russia's further invasion of Ukraine on February 24, 2022. The entities were designated as military end users acquiring or attempting to acquire US-origin items in support of Russia's military, and are subject to a policy of denial for all items subject to the Export Administration Regulations (EAR). Sixty-six entities receive a "footnote 3" military end-user designation, while five face outright denial with no license exceptions available beyond humanitarian food and medicine.

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.

The Act on the Promotion of Ensuring National Security through Integrated Implementation of Economic Measures (Law No. 43 of 2022), enacted 18 May 2022, establishes a four-pillar framework: (1) supply-chain resilience for "specified critical products," (2) security of critical infrastructure, (3) state-backed development of "specified critical technologies," and (4) non-disclosure of nationally sensitive patents. A December 2022 Cabinet Order designated 11 product categories as specified critical products, including semiconductors, storage batteries, permanent magnets, cloud programs, LNG, critical minerals, machine tools, and aircraft parts. Competent ministries must publish stable-supply plans, can fund private-sector surveys, and may provide subsidies to qualifying firms.

The Wet veiligheidstoets investeringen, fusies en overnames ("Vifo Act") is the Netherlands' cross-sector statutory FDI screening regime. Adopted by the States-General on 18 May 2022 (Stb. 2022, 215) and entered into force on 1 June 2023 together with two implementing decrees (Stb. 2023, 173 — main implementing decree; Stb. 2023, 172 — decree defining the scope of "sensitive technology"), the Act establishes mandatory pre-closing notification and a security review by the Bureau Toetsing Investeringen (BTI, part of the Ministry of Economic Affairs and Climate) for transactions affecting (i) "vital providers" in critical infrastructure sectors — energy, transport, telecoms, port operators, banking infrastructure — and (ii) Dutch undertakings active in "sensitive technology", defined to include EU Reg 2021/821 Annex I dual-use items, military goods, and additional national-security technologies. The regime applies retrospectively to transactions completed after 8 September 2020. It is the foundational instrument under which the Dutch national export-control measures on ASML DUV immersion lithography (filed: 2023-06-30 and 2024-09-07) operate, and the Dutch peer of US CFIUS, EU Regulation 2019/452, the German AWG §§55-62, the French Décret 2014-479 / R. 151-1 et seq., and the UK NSI Act 2021.

The U.S. Department of Commerce Bureau of Industry and Security (BIS) expanded export-control sanctions on Russian industry by adding 205 HTS codes (478 Schedule B numbers) to Supplement No. 4 to Part 746 of the EAR, imposing a license requirement — with a presumption of denial — for all exports, reexports, and transfers (in-country) to or within Russia of covered industrial goods. The targeted categories span wood products, boilers, industrial machinery, pumps, compressors, textile and grinding equipment, and hydraulic motors, aligning U.S. controls with EU partner lists. The rule took retroactive effect May 9, 2022, two days before Federal Register publication on May 11, 2022.

On 20 April 2022 Mexico's Diario Oficial de la Federación published a reform to the Ley Minera (Mining Law) declaring lithium "patrimonio de la Nación" (national patrimony) and of public utility, adding Article 5 Bis to state that no further concessions, licenses, contracts, permits or authorizations for lithium exploration, exploitation, benefit or use will be granted to private parties — reserving the entire value chain exclusively to the State (Articles 1, 9 and 10 also amended). On 23 August 2022 a follow-on decree created "Litio para México" (LitioMx), a decentralized public agency governed by a board of five cabinet secretaries (Energy as chair, plus Finance, Economy, Interior and Environment) and technically supported by the Mexican Geological Service, holding exclusive rights to explore, exploit and commercialize Mexico's lithium deposits. The law was subsequently upheld as constitutional by Mexico's Supreme Court in March 2026 (Acción de Inconstitucionalidad 78/2022, filed separately).

The Bureau of Industry and Security (BIS) issued a final rule expanding license requirements under the EAR for all items on the Commerce Control List (CCL) destined for Russia and Belarus, retroactively effective April 8, 2022. The rule also removes certain license exceptions that previously allowed aircraft-related transactions involving Belarus to proceed without authorization. Issued in direct response to Russia's continued aggression in Ukraine and Belarus's role in enabling it, this measure substantially tightens the multilateral export- control perimeter first established by BIS in late February 2022.

METI committed 476 billion yen (~$3.3bn) in direct subsidies covering approximately half the construction cost of Japan Advanced Semiconductor Manufacturing K.K. (JASM), a purpose-built joint venture fab at Kikuyo Town, Kumamoto Prefecture. JASM shareholders are TSMC (86.5%), Sony Semiconductor Solutions (6%), Denso (6%), and Toyota Motor (1.5 %). The fab manufactures 12nm, 16nm, 22nm, and 28nm mature-node chips targeting automotive-grade, industrial, and IoT applications. A groundbreaking ceremony was held on 13 April 2022; the facility officially opened on 24 February 2024 and reached commercial production in December 2024. JASM represents Japan's first new leading-edge wafer fab in decades and the largest single foreign direct investment in Japanese manufacturing history.

On 8 April 2022 the Council of the European Union adopted Regulation (EU) 2022/576, further amending Regulation (EU) No 833/2014 (the fifth package of measures against Russia). It bans imports of Russian coal and other solid fossil fuels, wood, cement, rubber, fertilisers, high-end seafood and spirits; bans exports to Russia of jet fuel, quantum computers, advanced semiconductors, high-end electronics and sensitive machinery; bars Russian and Belarusian road-freight operators from EU territory; and closes EU ports to Russian-flagged vessels. It entered into force on 9 April 2022, the day after publication in the Official Journal (OJ L 111).

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 120 entities under 120 entries to the Entity List, effective 1 April 2022 and published in the Federal Register on 7 April 2022. All 120 entities — located in Russia and Belarus — were determined to be acting contrary to US national security or foreign policy interests in the context of Russia's further invasion of Ukraine beginning 24 February 2022. The rule imposes a presumption-of-denial policy for all EAR-subject items and prohibits all license exceptions for exports, reexports, or in-country transfers to the listed parties. Ninety-five of the 120 entities are additionally designated under Footnote 3 of the Entity List as military end users, triggering the Russian/Belarusian Military End User foreign-produced direct product rule (MEU FDP Rule), extending US extraterritorial reach to non-US items made with US-origin technology.

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.

Canada amended the Special Economic Measures (Russia) Regulations via SOR/2022-067, registered and in force 24 March 2022, establishing a new "Restricted Goods and Technologies List" and prohibiting any person in Canada, and any Canadian outside Canada, from exporting, selling, supplying or shipping any listed good or technology to Russia or to any person in Russia. The list is maintained and published separately by Global Affairs Canada and covers items with dual civilian/military applications across electronics, computers, telecommunications, sensors and lasers, navigation and avionics, marine, aerospace and transportation equipment.

Australia designated aluminium ores (including bauxite), alumina and aluminium hydroxide as "export sanctioned goods" for Russia under the Autonomous Sanctions (Export Sanctioned Goods -- Russia) Designation 2022, banning their export from Australia to Russia effective 20 March 2022. Prime Minister Scott Morrison announced the measure a day earlier as part of Australia's response to the invasion of Ukraine, framing it as an attack on Russia's aluminium industry, which sourced roughly 20% of its alumina from Australian supply. Rusal, Russia's dominant aluminium producer, was identified as the primary target.

On 15 March 2022 the Council of the European Union adopted Regulation (EU) 2022/428, amending Regulation (EU) No 833/2014 (the fourth package of measures against Russia). It bans imports, purchase and transport of the iron and steel products listed in a new Annex XVII that originate in or are exported from Russia, bans the sale or export of Annex XVIII luxury goods to Russia (above EUR 300 per item unless otherwise specified), and prohibits transactions with the Russian state-controlled entities listed in Annex XIX. The Regulation entered into force on the day after its publication in the Official Journal (OJ L 87 I, 15.3.2022), i.e. 16 March 2022.

The Department of Commerce Bureau of Industry and Security (BIS) added 91 entities (across 96 entries) to the Entity List under 15 CFR Part 744, in direct response to Russia's further invasion of Ukraine on 24 February 2022. The listed entities span ten destinations — Belize, Estonia, Kazakhstan, Latvia, Malta, Russia, Singapore, Slovakia, Spain, and the United Kingdom — and include Russian military research institutes, shipbuilding facilities, aerospace and electronics manufacturers, and suspected front companies in third countries used to circumvent EAR controls. A license is required for all items subject to the EAR; the review policy is denial for 86 entities and case-by-case (for US Government-supported space programs) for five.

Effective 3 March 2022 (retroactive to five days before Federal Register publication), the US Bureau of Industry and Security (BIS) expanded Russian Industry Sector Sanctions under the Export Administration Regulations (EAR) by adding a new license requirement and denial policy for oil refinery equipment destined for or within Russia. The rule creates 15 CFR § 746.5(a)(1)(ii) and a new Supplement No. 4 to Part 746 enumerating approximately 20 categories of refining equipment — from crude distillation units and catalytic crackers to hydrocracking reactors and sulphur recovery units. Applications are subject to a policy of denial, with a narrow health-and-safety exception reviewed case by case. The stated rationale is to limit Russia's ability to generate oil-derived government revenues used to finance its military operations in Ukraine.

On 4 March 2022 Switzerland's Federal Council adopted a total revision of the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), taking effect the same day at 18:00, to fully implement the EU's sanctions packages of 23 and 25 February 2022. The revision bans export of all dual-use goods to Russia regardless of end use or end user, bans export of goods that could contribute to Russia's military or technological strengthening or its defence and security sector, and prohibits export of specified goods and services to the oil sector, as well as goods for aviation, space and oil-refining/gas-liquefaction use.

Effective 2 March 2022, the US Bureau of Industry and Security (BIS) extended to Belarus the same sweeping EAR sanctions imposed on Russia following Russia's full-scale invasion of Ukraine on 24 February 2022. The rule adds Commerce Control List (CCL)-based license requirements for Belarus with a policy of denial across virtually all categories, extends both the Russia Foreign Direct Product (FDP) rule and the Russia Military End User (MEU) FDP rule to cover Belarus and Belarusian military end users, and aligns Belarus with Russia's license review policy. The action was triggered by Belarus's active enablement of the Russian military operation from its territory.

On 1 March 2022, OFAC published an interim final rule adding the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR) at 31 CFR Part 587, codifying into Title 31 of the Code of Federal Regulations all prohibitions previously imposed by Executive Order 14024 of 15 April 2021. The regulations were issued in abbreviated form to provide immediate public guidance, with OFAC indicating an intent to supplement them with additional definitions, general licenses, and interpretive guidance. All transactions prohibited under EO 14024 — including prior sectoral determinations and directives targeting Russia's financial services sector, sovereign debt markets, and key state institutions — are formally prohibited under Part 587, giving domestic courts and compliance teams a stable regulatory anchor.

On 25 February 2022, the day after Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Regulation (EU) 2022/328, amending Regulation (EU) No 833/2014. It prohibits the sale, supply, transfer or export of dual-use goods and technology to any person, entity or body in Russia, or for military use or military end-users there, and extends to goods and technology suited for use in the oil refining industry and for the aviation and space industry, alongside a ban on related technical assistance, brokering, financing and insurance/maintenance services. The Regulation entered into force on the day after its Official Journal publication (OJ L 49, 25.2.2022), i.e. 26 February 2022.

On 24 February 2022, hours after Russia's invasion of Ukraine began, the UK Foreign Secretary announced a full asset freeze on VTB, Russia's second-largest bank (£154bn in assets, 95,000 employees), alongside a freeze on all Russian bank assets in the UK and a ban on Russian companies raising finance on UK markets. The package designated more than 100 companies and individuals -- including five major defence firms (Rostec, Uralvagonzavod, Tactical Missile Corporation, United Aircraft Corporation, United Shipbuilding Corporation) and Putin-inner-circle figures such as Kirill Shamalov -- for asset freezes and travel bans. Aeroflot was banned from UK airspace and new export controls were imposed on electronics, telecommunications and aerospace goods to Russia.