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

President Trump signed Executive Order 14323, "Addressing Threats to the United States by the Government of Brazil," on 30 July 2025 (published in the Federal Register on 5 August 2025 as FR doc 2025-14896). Invoking IEEPA and the National Emergencies Act, the order declared a country- specific national emergency citing "policies, practices, and actions" of the Lula government — including the criminal prosecution of former president Jair Bolsonaro, asserted infringement of the free-expression rights of US persons via DSA-style platform-content rules, and retaliatory measures targeting US digital firms — as constituting an "unusual and extraordinary threat" to US national security, foreign policy, and economy. The EO imposed a 40% additional ad valorem duty on Brazilian-origin goods effective for entries on or after 12:01 a.m. EDT on 6 August 2025; stacked on top of the 10% baseline reciprocal rate from EO 14257/14326, the cumulative rate reached 50% for non- exempt goods. Annex I exempted civil aircraft and parts, orange juice, certain machinery, certain metals, and energy/energy products. The EO was amended on 20 November 2025 (effective for entries on or after 13 November 2025) to exempt 238+ HTSUS codes for agricultural products (beef, tropical produce, nuts, coffee, cocoa, cassava derivatives, etc.) following initial Trump-Lula bilateral negotiations on 6 October 2025. The IEEPA-tariff component was terminated by EO of 20 February 2026 ("Ending Certain Tariff Actions") within hours of the SCOTUS 6-3 ruling in *Learning Resources, Inc. v. Trump* holding that IEEPA does not authorize the imposition of tariffs.

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 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.

The Sanctions and Anti-Money Laundering Act 2018 (SAMLA, Chapter 13) received Royal Assent on 23 May 2018 and established the UK's autonomous post-Brexit sanctions legal framework. Part 1 empowers Ministers (FCDO, HM Treasury) to impose financial, trade, immigration, aircraft, and shipping sanctions by statutory instrument for purposes including UN compliance, national security, foreign-policy objectives, and promotion of human rights and democracy. Part 2 grants Ministers authority to make AML and counter-terrorist-financing regulations aligned with FATF standards, previously derived from EU Anti-Money-Laundering Directives. SAMLA is the parent enabling statute for every UK sanctions regime in force post-Brexit, including 30+ thematic and geographic regulations covering Russia (SI 2019/855), Iran, DPRK, Belarus, Myanmar, Syria, Venezuela, cyber, chemical weapons, global anti-corruption, and global human rights; under SAMLA, OFSI (HM Treasury) holds civil monetary-penalty and criminal-referral enforcement powers. Structurally peer to US IEEPA, EU Council Regulation framework, CN AFSL 2021, and JP FEFTA as the G7+CN foundational sanctions-statute cluster.