Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

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 15 October 2025 the UK Foreign, Commonwealth & Development Office, acting under the Russia (Sanctions) (EU Exit) Regulations 2019, designated 39 entities and specified 51 vessels — including, for the first time, Russia's two largest integrated oil majors PJSC Rosneft Oil Company and PJSC Oil Company Lukoil — for supporting Russia's energy, defence and financial sectors. 51 vessels (44 identified as "shadow fleet" tankers) were specified for transporting Russian crude oil and LNG in evasion of the G7 price cap. The package also introduced a ban on importing oil products refined in a third country from Russian-origin crude, closing a refined-product loophole in the price-cap regime.

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.

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 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.

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.

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.

Between 22 and 28 February 2022 — coinciding with Russia's full-scale invasion of Ukraine — OFAC issued a Financial Services Sectoral Determination and four directives under Executive Order 14024 of April 15, 2021. Together they authorise designation of any person operating in Russia's financial sector, prohibit US persons from trading Russian sovereign debt, bar US banks from maintaining correspondent accounts for designated Russian financial institutions (Sberbank, Alfa-Bank and others), prohibit new investment in certain Russia-related entities, and block all transactions involving the Central Bank of the Russian Federation, the National Wealth Fund, and the Ministry of Finance — effectively freezing approximately USD 640 billion in Russian sovereign reserves held in Western financial systems. The package was formally published in the Federal Register on 31 May 2022.

Russia Federal Law No. 127-FZ of 4 June 2018 "On measures (countermeasures) regarding the unfriendly actions of the United States of America and other foreign states" establishes the statutory authority under which the President and Government of the Russian Federation may impose counter-measures against states that engage in "unfriendly actions" toward Russia. The law enumerates permissible countermeasure categories — including import/export prohibitions, restrictions on foreign participation in Russian state procurement, suspension of international cooperation obligations, and prohibition of foreign-company services and transactions — and delegates implementation authority to the President (primary) and Government. It entered into force on the day of official publication (4 June 2018) and is the foundational parent statute for every major Russian counter-sanctions presidential decree and government resolution subsequently issued, including the gas-for-roubles payment regime, capital controls, parallel- imports authorisation, and asset-confiscation counter-mechanism.

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.

The Autonomous Sanctions Act 2011 (Cth Act No. 38 of 2011; assented 12 April 2011, commenced 6 December 2011 with the Autonomous Sanctions Regulations 2011) is Australia's foundational parent statute enabling the entire autonomous sanctions regime — economic and travel measures imposed unilaterally by Australia independently of UN Security Council mandatory obligations. The Minister for Foreign Affairs may, by legislative instrument, impose targeted financial sanctions, travel bans, and vessel-dealing prohibitions on designated persons, entities, and vessels. As of 2026 the Act underpins Australia's autonomous sanctions programs against Russia, Iran, DPRK, Myanmar, Belarus, Syria, Venezuela, Zimbabwe, Libya, Ukraine (occupied territories), and other regimes, and was materially extended in December 2021 to authorise Magnitsky-style thematic human-rights and corruption sanctions. Structurally peer-foundational to the UK Sanctions and Anti-Money Laundering Act 2018 (SAMLA), Canada's Special Economic Measures Act 1992 (SEMA), Japan's FEFTA sanctions provisions, and the EU's Anti-Coercion Instrument — the ASA 2011 completes the G7+AU sanctions-parent-statute set in the IPTM register.

Canada's Special Economic Measures Act (SEMA, S.C. 1992, c. 17; assented 4 June 1992) is the foundational umbrella statute enabling the entire Canadian autonomous sanctions regime — economic measures imposed by Canada independently of UN Security Council mandatory obligations. The Governor in Council may, on the recommendation of the Minister of Foreign Affairs, make regulations against a foreign state and its nationals or entities under four statutory triggers: (a) a grave breach of international peace and security causing or likely to cause a serious international crisis; (b) an international organisation or association of states to which Canada belongs has called for economic measures; (c) gross and systematic human-rights violations have been committed; or (d) acts of significant corruption by a foreign state's nationals or entities. As of the 2026-03-17 consolidation, 26 regulations are in force under SEMA targeting Russia, Ukraine (separatist entities), Iran, DPRK, Myanmar, Belarus, Syria, Venezuela, Zimbabwe, South Sudan, Libya, Haiti, Nicaragua, Moldova, and others — making SEMA the parent authority for the broadest multilateral-allied autonomous-sanctions toolkit outside the United States. Structurally peer-foundational to the UK Sanctions and Anti-Money Laundering Act 2018 (SAMLA), the CN Anti-Foreign Sanctions Law 2021, and Japan's FEFTA.

The International Emergency Economic Powers Act of 1977 (IEEPA, Title II of Pub. L. 95-223, 91 Stat. 1626, codified at 50 U.S.C. §§ 1701–1708) was signed by President Carter on 28 December 1977 and grants the President sweeping authority to declare a national emergency with respect to "any unusual and extraordinary threat, which has its source in whole or substantial part outside the United States, to the national security, foreign policy, or economy of the United States" — and then to investigate, regulate, direct, compel, nullify, void, prevent, or prohibit any transaction in, or involving, foreign exchange, banking transfers, importing, exporting, or dealings in property by persons subject to US jurisdiction. IEEPA is the parent enabling statute for every OFAC-administered autonomous sanctions program (Russia, Iran, DPRK, Venezuela, Cuba, Syria, Belarus, Myanmar, cyber, Global Magnitsky, Hong Kong, ICC, and others) as well as the legal basis for the entire Trump-era IEEPA-tariff regime (EO 14193–14195 fentanyl tariffs, Canada/Mexico/China; EO 14257 reciprocal-tariff framework; EO 14323 Brazil; EO 14380 Cuba; EO 14382 Iran; and the US-India interim tariff agreement). Between 1977 and 2025 Presidents invoked IEEPA in 77 national-emergency declarations; of these, 7+ directly parent IPTM-filed implementing actions, with ~dozens of OFAC SDN designation actions tracing their legal root to this statute.