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

On 23 February 2024, two years after Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Council Regulation (EU) 2024/745, amending Regulation (EU) No 833/2014 and comprising the EU's 13th Russia sanctions package. It adds new CN codes to the export-ban annexes (dual-use and advanced-technology goods) and adds 27 entities — including firms based in China, Hong Kong, India, Sri Lanka, Serbia, Kazakhstan, Thailand and Turkiye — to the list of parties barred from any exemption from the export ban, on the basis they are assessed to be supporting Russia's military-industrial complex via circumvention routes. Asset-freeze listings (106 individuals, 88 entities) under the parallel Council Decision took effect 23 February 2024; the sectoral trade measures took effect 24 February 2024.

BIS published a two-part final rule amending the Export Administration Regulations (EAR) for cameras, systems, and related components, effective March 8, 2024. Part one creates new ECCN 6A293 controlling ultra-high-speed cameras (minimum exposure time ≤1 microsecond AND throughput ≥13.43 Giga-pixels per second at 205,000 fps) for nuclear nonproliferation (NP) reasons with no License Exception STA eligibility, capturing instruments used in weapons-test diagnostics not previously covered by 6A003 or 6A203. Part two lifts military-end-user (MEU) restrictions on ECCNs 0A504, 6A002, 6A003, 6A993.a, and 8A002.d for Country Group A:1 destinations (32 closest US allies including EU member states, Canada, Japan, Australia, UK, and South Korea), aligning controls with commercial availability and established allied strategic relationships.

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.

Canada made SOR/2024-32, Regulations Amending the Special Economic Measures (Russia) Regulations, registered and effective 2024-02-21 on the second anniversary of Russia's invasion of Ukraine. The regulations add 163 persons to Schedule 1 — 10 individuals and 153 entities, predominantly Russian organizations tied to military-industrial production, logistics, insurance and oil-sector support — triggering Canadian dealing/asset bans. A parallel amendment to Schedule 7 adds five new goods categories under the Harmonized System (explosives and pyrotechnics; data-processing units and components; ball and roller bearings; semiconductor manufacturing equipment; optical and navigational instruments), banning their export to Russia or Russian persons.

Ministerial order signed by the French Minister of Economy on 2 February 2024 and published in JORF n°0034 of 10 February 2024 establishing France's first national export-control list under Article 9 of EU Regulation 2021/821 on dual-use goods. The arrêté requires prior authorisation for exports to non-EU third countries of (i) quantum computers and their enabling technologies (qubit devices, control systems, measurement equipment) and (ii) equipment for the design, development, production, test and inspection of advanced electronic components, plus associated software and technology. The annex was substantively replaced by the Arrêté du 27 mars 2025 (explicit technical thresholds including ≥34-qubit systems with C-NOT error ≤10⁻⁴, HBM 6000+ processing performance, cryogenic cooling, dry-etch and EUV-mask tooling, and Si-28/Si-30/Ge isotopically-controlled materials) and is repealed by the Arrêté du 10 mars 2026 with entry into force 11 May 2026.

BIS final rule (FR Doc 2024-01408, 89 FR 4804, effective 23 January 2024) strengthens the EAR sanctions architecture against Russia and Belarus by adding 94 HTS-6 entries to the Russian and Belarusian Industry Sector Sanctions (§746.5/§746.8) — covering hand tools, parachutes, aircraft training simulators, and airplane/helicopter components — and expands the de minimis threshold for foreign-made goods incorporating US-origin 600-series and 9×515 items destined for Russia or Belarus. A parallel provision targets Iran's supply of unmanned aerial vehicles (UAVs) to Russia by adding HTS code 852910 (antennas and antenna reflectors) to the §746.7 Iran export-control list. The rule also refines Crimea licensing to permit exports supporting Ukrainian Armed Forces deployments in occupied territories.

The Bureau of Industry and Security (BIS) removed three persons from the Unverified List (UVL) effective January 19, 2024 because BIS was able to verify their bona fides pursuant to § 744.15(c)(2) of the EAR. The three removed parties are Skymount Drones (Canada), Plexus (Xiamen) Co., Ltd. (China), and Delma Industrial Supply & Marine Services (UAE). Removal restores eligibility for EAR license exceptions and removes the requirement for a signed UVL Statement before US exporters ship items subject to the EAR to these parties.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 13 persons to the Unverified List (UVL), all located in the People's Republic of China, on the basis that BIS was unable to verify their bona fides through end-use checks. UVL placement suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement before exporting any item subject to the EAR. A grace period applies for items already in transit: shipments commenced before 18 January 2024 may proceed under prior conditions. Published 20 December 2023 (88 FR 87897, FR Doc 2023-27928); effective 19 December 2023.

The Bureau of Industry and Security (BIS) removed four Chinese entities from the Unverified List (UVL) effective 15 December 2023, after successfully verifying their bona fides pursuant to § 744.15(c)(2) of the Export Administration Regulations (EAR). The four entities span oscillator electronics (Chengde), heavy industrial machinery (Erzhong), laser systems (Ningbo), and new-energy manufacturing (Xinjiang). Removal restores eligibility for EAR license exceptions and eliminates the requirement for a signed UVL Statement before US exporters ship EAR-subject items to these parties.

On 8 December 2023 the Bureau of Industry and Security (BIS) published a direct final rule (88 FR 85479; FR Doc 2023-26532) making two export-liberalisation amendments to the Export Administration Regulations (EAR). First, BIS removes Chemical and Biological Weapons (CB) proliferation column controls from the Commerce Country Chart for exports of certain pathogens and toxins (ECCNs 1C351, 1C353, and 1C354) when destined to Australia Group (AG) member countries, on the basis that AG members operate equivalent domestic CBW-export controls. Second, the rule revises the Crime Control and Detection (CC) column entries for Austria, Finland, Ireland, Liechtenstein, South Korea, Sweden, and Switzerland, reflecting the updated US assessment of those countries' law-enforcement export-control standards. Both changes are effective on publication and reduce US export-licensing burdens for allied-country destinations without altering controls for non-allied markets.

Ireland's Screening of Third Country Transactions Act 2023 (Act No. 28 of 2023), signed into law on 31 October 2023 and commenced on 6 January 2025 via S.I. No. 651 of 2024, establishes Ireland's first-ever mandatory inbound FDI screening regime. The Act empowers the Minister for Enterprise, Tourism and Employment to assess, condition, or prohibit transactions by third-country investors (non-EU/EEA/Switzerland) exceeding a EUR 2 million cumulative threshold in targets operating across critical infrastructure, critical technologies, dual-use items, supply of critical inputs, sensitive personal data, and media freedom. A 90-day standstill period applies during Ministerial determination, with criminal sanctions and transaction-voiding powers available for non-compliance.

China's Ministry of Commerce and General Administration of Customs jointly announced (Announcement No. 33 of 2023) export-licensing controls on graphite products, effective 1 December 2023. The regime covers natural flake graphite and products thereof (including spherical graphite and graphite powder used in lithium-ion battery anodes) as well as high-purity, high-hardness, and high-strength synthetic graphite materials. Exporters must obtain dual-use-item licences from MOFCOM citing end-user and end-use; licences are granted at MOFCOM's discretion. The announcement came three days after the 17 October 2023 BIS advanced-chip-controls expansion, continuing the proportional-response pattern established with Ga/Ge in July.

On 18 October 2023 the Governor in Council registered Regulations Amending the Special Economic Measures (Iran) Regulations (SOR/2023-220) under the Special Economic Measures Act, citing Iran's proliferation- sensitive nuclear activities and weapons-of-mass-destruction-related programme as a grave breach of international peace and security. The amendment prohibits Canadians and Canadian entities from exporting, selling or supplying to Iran dual-use goods and technology, conventional arms (battle tanks, armoured combat vehicles, large-calibre artillery, combat aircraft, attack helicopters, warships), Missile Technology Control Regime-listed equipment, and technical data related to ballistic missiles and nuclear-weapon delivery systems; it also bars importing arms and related material from Iran. The same instrument adds 156 entities and 18 individuals to Canada's Iran sanctions list (asset freeze / dealings prohibition).

BIS added 28 entities to the EAR Entity List across seven countries, targeting four distinct threat clusters: a Russia GRU/UAV diversion network spanning China, Finland, Germany, and Russia; an Iran Shahed-series UAV procurement chain operating through Chinese front companies (designated under the Russia/Belarus Military End User FDP Rule); Pakistan-linked suppliers procuring for unsafeguarded nuclear activities; and two Oman-based entities supporting Yemen's Houthi forces. Russia's dominant titanium producer VSMPO-AVISMA was also added as a military end user. One Chinese entity (Zhejiang Perfect New Material) was simultaneously removed from the Military End User List.

Sweden's first horizontal foreign-direct-investment screening regime. Lag (2023:560) om granskning av utländska direktinvesteringar — promulgated (utfärdad) by the Ministry of Justice on 21 September 2023 on the basis of Government Bill 2022/23:116, and entered into force on 1 December 2023 — establishes mandatory ex-ante notification to Inspektionen för strategiska produkter (ISP) for direct or indirect acquisitions of voting rights of ≥10%, 20%, 30%, 50%, 65%, or 90% in Swedish entities conducting "skyddsvärd verksamhet" (protected business activities). The protected-activity perimeter is defined by Förordning (2023:624) and the ISP listing across seven sub-categories: essential services, security-sensitive activities, critical raw materials/metals/ minerals, sensitive location and personal data, military equipment, dual-use goods, and emerging or strategically protected technologies. Both EU and non-EU investors are within scope. Unnotified transactions are void by operation of law and may carry administrative fines of SEK 25,000 to SEK 100 million. From 1 Dec 2023 to 29 Nov 2024 ISP processed 1,206 notifications, opened 24 deeper screenings, approved 11, approved 5 with conditions, and prohibited 1 transaction.

The Bureau of Industry and Security (BIS) removed 35 persons from the Unverified List (UVL) effective 22 August 2023, spanning seven destinations: 27 entities in China, plus one each in Indonesia, Singapore, Turkey, and UAE; two in Pakistan; and two Russian entities removed as a conforming change after being escalated to the more restrictive Entity List. The 33 cooperative removals follow successful completion of end-use checks verifying each party's bona fides under §744.15(c)(2) of the EAR. Removal restores eligibility for EAR license exceptions and eliminates the UVL Statement requirement for US exporters shipping EAR-subject items to these parties.

BIS published a final rule on August 18, 2023, amending the Export Administration Regulations (EAR) to implement decisions reached at the Nuclear Suppliers Group (NSG) plenary meetings in Nur-Sultan (June 2019) and Warsaw (June 2022). The rule revises five existing Export Control Classification Numbers (ECCNs) on the Commerce Control List (CCL) to align with multilateral commitments made by NSG participating governments. Changes include decontrolling water-hydrogen sulfide exchange tray columns from ECCN 1B22, clarifying isotope purification scope in ECCN 1B231, and updating mass-unit terminology in ECCN 3A233. The rule takes effect immediately upon publication.

On 16 August 2023 the Swiss Federal Council amended the Ordinance of 4 March 2022 on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), aligning with the EU's 11th Russia sanctions package. The amendment adds two UAE-headquartered firms to the list of entities barred from exemptions to Switzerland's dual-use export ban on Russia, restricts the sale of securities issued after 6 August 2023 to Russian nationals, residents, entities and businesses regardless of currency, and adds 12 individuals and 87 entities to the asset-freeze list, targeting dual-use/military-tech exporters, FSB-licensed IT firms, propagandists and government officials. It entered into force the same day at 18:00 CEST.

Bureau of Industry and Security final rule (88 FR 46071, Doc 2023-15343) adding four entities to the Entity List effective July 18, 2023. Intellexa S.A. (Greece) and Intellexa Limited (Ireland) — the corporate architecture behind the "Predator" commercial spyware platform — and Cytrox Holdings Zrt. (Hungary) and Cytrox AD (North Macedonia) — the developer of the underlying spyware technology — were listed for "trafficking in cyber exploits used to gain access to information systems, thereby threatening the privacy and security of individuals and organizations worldwide." All items subject to the EAR require a license with a presumption-of-denial review policy for all four entities, effectively cutting off access to US-origin hardware, software, and technology.

Luxembourg's Chambre des Députés adopted the first-ever national FDI-screening statute on 14 July 2023 (promulgated by the Grand Duke and published in Mémorial A n° 411 on 18 July 2023), entering into force 1 September 2023. The law requires non-EU investors to notify the Ministre de l'Économie before completing direct or indirect acquisitions of ≥25% voting rights / equity in Luxembourg entities engaged in "critical activities" across twelve sectors. The Minister can approve, conditionally approve, or prohibit transactions within a two-month initial screening window, with a further 60-day deep-review phase available; an inter-ministerial Comité de filtrage (Economy + Foreign Affairs + Finance + SREL intelligence service) advises on security and public-order grounds consistent with EU Regulation 2019/452.

Spain's comprehensive 2023 implementing regulation of Law 19/2003, of 4 July, on the legal regime of capital movements and economic transactions with the exterior. Adopted as Real Decreto 571/2023 of 4 July 2023, published in the Boletín Oficial del Estado on 5 July 2023 (BOE-A-2023-15549), and in force from 1 September 2023. The Decree repeals the predecessor Royal Decree 664/1999 of 23 April on foreign investments, updates the declaration regime to reflect twenty years of practice and capital-market innovation, and operationalises the Article 7-bis horizontal FDI-screening mechanism that the 2020 COVID-emergency reforms (RDL 8/2020 and RDL 11/2020) inserted into Law 19/2003. It introduces a binding consultation regime (consulta vinculante), reduces the screening review period to three months, refines the catalogue of sensitive sectors (defence, dual-use, critical technologies, critical infrastructure, critical inputs, media, electoral process, access to sensitive information, and activities affecting public security, health and order), and codifies notification thresholds for non-EU/EFTA investors (>10% control or material influence; minimum transaction values of EUR 5 million / EUR 1 million for certain sectors).

China's Ministry of Commerce and General Administration of Customs jointly announced an export licensing regime covering eight gallium-related items (including gallium metal, gallium arsenide, gallium nitride wafers and ingots) and six germanium- related items (including germanium metal, germanium oxide, germanium tetrachloride). Effective 1 August 2023, exporters must obtain a dual-use-item licence from MOFCOM citing the end-user and end-use, with licences granted at MOFCOM's discretion. The measure was framed as protecting national security and interests, though the timing immediately followed the Dutch ASML DUV controls and US chip-equipment escalations.

On 23 June 2023 the Council of the European Union adopted Council Regulation (EU) 2023/1214, amending Regulation (EU) No 833/2014 and comprising the EU's 11th Russia sanctions package. It extends the list of goods generating significant revenue for Russia subject to import bans, adds further export-ban categories (including additional industrial goods, dual-use and advanced-technology items), and introduces a new anti-circumvention tool (Article 12g) allowing the EU to restrict exports of specified sanctioned goods and technology to third countries assessed as high-risk transshipment routes for Russia. Asset-freeze listings under the parallel Council Decision took effect 23 June 2023; the sectoral trade measures took effect 24 June 2023.

BIS issued a correcting amendment to the EAR Entity List to add China Aviation Development Harbin Bearing Co., Ltd. — an AVIC subsidiary and specialist precision-bearing manufacturer — that was included in the preamble of the June 14, 2023 final rule (88 FR 38739) but inadvertently omitted from the regulatory text. The entity was designated for acquiring and attempting to acquire US-origin items in support of China's military modernization, including hypersonic weapons development, air-to-air missiles, and weapon lifecycle management using Western software. All EAR-subject items require a licence with a presumption of denial; retroactive effective date of June 16, 2023.

Lov 2023-06-20 nr. 77 (Lov om endringer i sikkerhetsloven — eierskapskontroll og lovens virkeområde), adopted by the Storting on 9 June 2023, signed 20 June 2023, in force 1 July 2023, is Norway's first substantive overhaul of Chapter 10 (Eierskapskontroll / ownership control) of the 2018 Security Act (Sikkerhetsloven). The amendment widens the scope of undertakings that can be brought under ownership control beyond entities directly linked to a "grunnleggende nasjonal funksjon" (fundamental national function) to include businesses of vital importance to national-security interests and businesses of significant importance to fundamental national functions, lowers and adds notification thresholds, and equips the King in Council with enhanced powers to block, condition, or unwind qualifying acquisitions. The reform converts a narrow security-classified regime into a broad horizontal FDI-screening architecture for Norway, the host of the world's largest sovereign wealth fund and a NATO frontline state.

BIS published a final rule adding 43 entities under 50 entries to the EAR Entity List and removing one entity (Fiber Optic Solutions, Latvia), effective June 12, 2023. The additions span ten countries — China (31 entities), UAE (5), Pakistan (4), South Africa (3), UK (2), and one each in Kenya, Laos, Malaysia, Singapore, and Thailand — targeting four principal threat clusters: China's military modernization and hypersonic-weapons supply chain, an international network of flight-training academies (TFASA and affiliates) providing Western pilot training to Chinese military personnel, Pakistan-linked procurement for unsafeguarded ballistic-missile programs, and UAE/South Africa-based dual-use diversion networks. All listed entities require a BIS licence, with most subject to a presumption of denial.

On 9 June 2023 the National Assembly of the Republic of Slovenia adopted Zakon o spremembah in dopolnitvah Zakona o spodbujanju investicij — ZSInv-C (Act on Amendments to the Investment Promotion Act), published in Uradni list RS No. 65/23 on 17 June 2023 and entering into force on 1 July 2023. The amendment converts Slovenia's temporary COVID-era inward FDI screening regime (originally introduced under ZIUOPDVE in 2020 and set to expire June 2023) into a permanent, horizontal screening framework administered by the Ministry of Economy, Tourism and Sport (MGTŠ). Non-EU (third-country) investors acquiring ≥10% voting rights or control in Slovenian entities operating in sectors listed under EU Regulation 2019/452 — including critical infrastructure, critical technology and dual-use goods, critical inputs, sensitive data, media, and health/AI/robotics — must submit a mandatory pre-closing notification; the ministry has suspensory power and may block, condition, or unwind transactions on grounds of security or public order. A subsequent 2024 amendment (Uradni list RS No. 31/24) broadened scope by redefining "corporate entity" to capture indirect investments channelled via branches of foreign entities established in other EU member states.

Law no. 164/2023, adopted by the Parliament of Romania on 31 May 2023 and published in Monitorul Oficial Partea I nr. 495 of 7 June 2023, approves and amends Emergency Government Ordinance 46/2022 implementing EU Regulation 2019/452 on screening of foreign direct investments. The law extends Romania's mandatory ex-ante FDI screening to investors established within the European Union (previously only non-EU investments were captured), sets a EUR 2 million de minimis transaction threshold for sensitive-sector deals, formally establishes the Commission for the Examination of Foreign Direct Investments (CEISD) chaired by the Prime Minister with multi-ministry composition, and empowers the Government to unwind transactions that breach the regime. Gun-jumping penalties reach up to 10 % of the investor's worldwide turnover. In force 10 June 2023.

Switzerland's Federal Council amended the Ordinance on measures related to the situation in Ukraine (SR 946.231.176.72) to align with the remainder of the EU's tenth sanctions package, effective 8pm on 29 March 2023. The amendment extends the existing Russia import ban to additional petroleum products (including petroleum jelly and petroleum coke), bitumen/asphalt, bituminous mastics, carbon and synthetic rubber, adds further export controls and designations linked to drone transfers to Russia, and tightens reporting obligations in the financial sector.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 32 persons across 13 countries to the Unverified List (UVL) on the basis that BIS was unable to verify their bona fides through end-use checks. The largest concentration is in China (14 entities), followed by the UAE (5) and Turkey (4), with single entries in Bulgaria, Canada, Germany, Indonesia, Israel, Malaysia, and Singapore. UVL placement suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement and file Electronic Export Information in the Automated Export System before shipping any item subject to the EAR. Published 24 March 2023 (88 FR 17706, FR Doc 2023-06171); effective 24 March 2023.

The Bureau of Industry and Security (BIS) added 10 entities under 13 destination entries to the Entity List, effective February 24, 2023. The additions span three groups: (1) five Chinese entities operating in the commercial satellite and dual-use space sector — most notably Spacety Co., Ltd. and China HEAD Aerospace Technology Co., both suspected of supplying satellite imagery and space technology in support of the Russian military in Ukraine; (2) two Canadian procurement intermediaries (CPUNTO Inc. and Electronic Network Inc.) facilitating illicit acquisition of US-origin controlled items; and (3) three Russian defense-industrial procurement companies supplying the Russian military. All listed entities are subject to a license requirement for all EAR-subject items with a policy of denial, except EAR99 food and medicine which receive case-by-case review.

On 25 February 2023, one year into Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Council Regulation (EU) 2023/427, the 10th package of sanctions, amending Regulation (EU) 833/2014. It entered into force on publication the following day (26 February 2023). The package bans imports of asphalt and synthetic rubber from Russia (with a temporary transitional import quota for rubber products running to 30 June 2024), expands the export ban on dual-use and advanced-technology goods, suspends further Russian media broadcasting licences in the EU, and designates 87 individuals and 34 entities — including Iranian persons and entities involved in drone manufacture and supply, and 96 entities tied to Russia's defence-industrial base — to the EU asset-freeze/travel-ban list.

The Bureau of Industry and Security expanded EAR sanctions against Russia and Belarus effective 24 February 2023, adding 322 HTS-6 industrial items to Supplement No. 4 to Part 746 (oil-and-gas equipment, flat-rolled steel, pumps, turbines, marine and aviation engines) and 276 luxury goods to Supplement No. 5. Supplement No. 6 was amended to add biological and chemical-synthesis equipment including bioreactors, peptide synthesizers, and nucleotide reagents, targeting Russia's biodefence and dual-use procurement pathway. The rule also migrated Supplement No. 2 from Schedule B to HTS-6 identifiers to align with allied partner frameworks, added Taiwan to the list of countries excluded from licence requirements, and extended Section 744.7 end-use restrictions to cover in-country transfers inside Russia and Belarus.

The Foreign Investment Reliability Assessment Act (välismaise investori usaldusväärsuse hindamise seadus, VUHS), adopted by the Riigikogu on 25 January 2023 and in force from 1 September 2023, establishes Estonia's first horizontal ex-ante foreign direct-investment screening regime. The Act transposes EU Regulation 2019/452 into Estonian law and designates the Consumer Protection and Technical Regulatory Authority (Tarbijakaitse ja Tehnilise Järelevalve Amet — TTJA) as the screening authority. It covers acquisitions of qualifying holdings or material influence in target undertakings operating in defence, dual-use, vital services, energy and communications infrastructure, transport, financial services, media, critical raw materials extraction and other strategic sectors. TTJA can prohibit, condition or unwind non-compliant transactions and impose administrative non-compliance levies.

Switzerland's Federal Council amended the Ordinance on measures related to the situation in Ukraine (SR 946.231.176.72) to align with the EU's ninth sanctions package, effective 6pm on 25 January 2023. The amendment bans new Swiss investment, equity provision, and participation (including joint ventures) in Russian mining-sector entities, with a carve-out for critical raw materials (aluminium/bauxite, chromium, cobalt, copper, iron ore, mineral fertilisers, molybdenum, nickel, palladium, rhodium, scandium, titanium, vanadium). It also extends export bans on aerospace goods to aircraft and drone engines, adds new controls on dual-use and military/security-enhancement goods, bans product testing/advertising/market-research services to Russia, and designates roughly 200 additional individuals and entities, including the Russian Regional Development Bank, to frozen-asset lists.

Commission Delegated Regulation (EU) 2023/66, adopted 21 October 2022 and published in the Official Journal on 11 January 2023 (OJ L 9), replaces Annex I of Regulation (EU) 2021/821 (the EU Dual-Use Recast Regulation) with an updated control list implementing the 2022 multilateral decisions of the Wassenaar Arrangement, MTCR, Australia Group, NSG and the Chemical Weapons Convention. Per GTA's tracking of the CN-code-level change, the update removed 7 six-digit CN codes and added 8 new ones. It entered into force on 12 January 2023, the day after publication.

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.

The US Bureau of Industry and Security (BIS) removed nine Russian persons from the Unverified List (UVL) and simultaneously added them to the Entity List after the Russian government failed to facilitate end-use checks for more than 60 days — the first application of BIS's October 2022 escalation policy. All nine entities are subject to a license requirement covering all items subject to the EAR, with a policy of denial and no license exceptions available. The list spans electronics traders, state maritime infrastructure, defense R&D, microelectronics, and industrial equipment manufacturers.

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.

On 19 October 2022, the US Treasury's Office of Foreign Assets Control (OFAC) designated Russian national Yury Yuryevich Orekhov, resident in Dubai, UAE, under Executive Order 14024 for operating a network that procured military and sensitive dual-use technology from Western suppliers for Russian end-users. Two entities tied to Orekhov were designated alongside him: NDA Nord-Deutsche Industrieanlagenbau GmbH, based in Hamburg, Germany, and Opus Energy Trading LLC, based in Dubai, UAE. The designation blocks all US property and interests of the designated persons and generally prohibits US persons from transacting with them.

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 U.S. Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 36 entities under 41 entries to the Entity List, effective June 28, 2022. The entities — located across China, Lithuania, Pakistan, Russia, Singapore, the UAE, the United Kingdom, Uzbekistan, and Vietnam — were designated for acting contrary to U.S. national security or foreign policy interests. Key grounds include support for China's military modernization and AI-enabled surveillance programs, Pakistan-based proliferation concerns, and supply-chain facilitation for Russia amid the Ukraine invasion. The rule also revised eleven existing entries (Belarus, China, Russia, Slovakia) and corrected one entry (Pakistan).

Canada amended the Special Economic Measures (Belarus) Regulations via SOR/2022-167, registered and in force 25 June 2022, adding four new schedules targeting Belarus over its support for Russia's invasion of Ukraine. Schedule 3 bans export of advanced technologies (quantum computers, advanced manufacturing and cryogenic equipment); Schedule 4 bans export of luxury goods (Part 1) and import of luxury goods from Belarus (Part 2); Schedule 5 bans export of goods usable in weapons manufacturing, including raw materials such as tungsten, aluminium and titanium, engines, industrial machinery, vehicles, aircraft and maritime vessels. The same instrument added 13 Belarusian officials and 2 state entities to the asset-freeze list.

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 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.

BIS amended the Export Administration Regulations to add Iceland, Liechtenstein, Norway, and Switzerland to the list of countries excluded from certain EAR license requirements that apply to items destined for Russia or Belarus. The exclusion recognizes that these four countries have implemented substantially similar export-control regimes aligned with US restrictions, and applies specifically to the Foreign Direct Product (FDP) rule under EAR Part 734.9. The change reduces the licensing burden for entities in these partner countries when producing or handling items using US-origin technology or equipment in transactions with Russia/Belarus, consistent with the broader allied coordination approach adopted after February 2022.

Canada amended the Special Economic Measures (Belarus) Regulations via SOR/2022-075, registered and in force 5 April 2022, in response to Belarus's support for Russia's invasion of Ukraine. The amendment prohibits any person in Canada and any Canadian outside Canada from providing insurance, reinsurance or underwriting services for aviation and aerospace products owned, controlled, registered to, chartered by or operated by Belarus or a Belarusian person. A new section 3.6 separately establishes export prohibitions on goods and technologies listed on a Belarus Restricted Goods and Technologies List, incorporated by reference, aligning Canada's Belarus measures with its parallel Russia export-control regime. The same instrument added nine individuals (Belarusian oligarchs and defence officials) to the Schedule 1 asset-freeze list, outside this action's scope.

On 4 April 2022 Australia's Minister for Foreign Affairs registered the Autonomous Sanctions (Export Sanctioned Goods—Russia) Amendment (No.1) Designation 2022, made under the Autonomous Sanctions Regulations 2011. It amended the existing Export Sanctioned Goods—Russia designation to add further categories of goods to the list of items whose export, supply or transfer to Russia is prohibited, extending an export-ban regime introduced in response to Russia's invasion of Ukraine. It took effect on registration.

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.