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

On 30 April 2025 the US Department of State designated seven entities and identified two vessels as blocked property for facilitating trade in Iranian petroleum and petrochemical products, under Executive Order 13846 and in furtherance of National Security Presidential Memorandum 2 (NSPM-2, "Restoring Maximum Pressure on the Government of Iran"). The action named four UAE-based sellers and one purchaser of Iranian petrochemicals — including Solvent Organics (over $300 million in exports of Iranian-origin petrochemicals to third countries) and Alseerah Trading (over $150 million) — plus a Turkiye-based petrochemical trader, an Iran-based cargo inspection company, and a marine management company involved in transporting millions of barrels of Iranian crude. Secretary of State Marco Rubio stated the goal was to drive Iran's illicit oil and petrochemical exports, including to China, to zero.

On April 29, 2025, the US Treasury's Office of Foreign Assets Control designated twelve Iran- and PRC-based entities and individuals under Executive Order 13382 for a network procuring ballistic-missile propellant ingredients for Iran's Islamic Revolutionary Guard Corps. Treasury names sodium perchlorate, dioctyl sebacate and sodium chlorate as the procured chemicals; sodium perchlorate is a precursor of ammonium perchlorate, which is MTCR-controlled. No shipment quantities or trade values were disclosed.

China's MOFCOM Unreliable Entity List Working Mechanism designated six US firms on 9 April 2025, effective 12:01 Beijing time 10 April 2025, under MOFCOM Order No. 4 of 2020. Cited trigger: participation in arms sales to Taiwan or military-technology cooperation with Taiwan in disregard of China's stated opposition, "seriously harming China's national sovereignty, security and development interests." Measures prohibit the six entities from import/export activities related to China, new investments in China, and impose entry/work-permit restrictions on senior management.

China's MOFCOM Unreliable Entity List Working Mechanism designated 11 US drone-sector companies on 4 April 2025 — Skydio Inc., BRINC Drones Inc., Kratos Unmanned Aerial Systems Inc., Insitu Inc., Red Six Solutions LLC, SYNEXXUS Inc., Firestorm Labs Inc., HavocAI, Neros Technologies, Domo Tactical Communications LLC, and Rapid Flight LLC — citing military-technology cooperation with Taiwan in violation of China's One-China principle. Designations prohibit the 11 firms from import/export activity related to China, bar new investments in China, and restrict senior-executive entry. Issued on the same date as the MOFCOM heavy rare-earth export-licensing measure, the designations formed a paired retaliation package responding to the 2 April 2025 US "Liberation Day" reciprocal-tariff escalation. On 15 May 2025 MOFCOM suspended the UEL restrictions on all 11 companies for 90 days in line with the US-China Geneva tariff truce.

Premier Li Qiang signed State Council Order No. 803 on 23 March 2025 promulgating the "Regulations on Implementation of the Anti-Foreign Sanctions Law of the People's Republic of China" (22 articles), effective on the date of publication (24 March 2025). The Regulations operationalise the 2021 Anti-Foreign Sanctions Law by clarifying the scope of countermeasure tools — explicitly extending "other property" subject to seizure to cash, bank deposits, securities, equity, intellectual property and accounts receivable, and listing the specific transaction and cooperation activities that may be prohibited or restricted (education, S&T, legal services, environment, trade, culture, tourism, health, sports, data and cross-border data transfers). They define inter-agency procedure, evidence and notice requirements for designations, and bind PRC organisations and individuals — including foreign-invested entities operating in China — to implement countermeasures, with sanctions including exclusion from government procurement, import/export and cross-border-data restrictions, and exit/stay restrictions for responsible persons.

OFSI imposed a £465,000 civil monetary penalty on Herbert Smith Freehills CIS LLP (the firm's Moscow subsidiary, "HSF Moscow") for six payments totalling £3,932,392.10 made to three Russia-designated persons — Alfa-Bank JSC, PJSC Sovcombank, and PJSC Sberbank — during the wind-down of the Moscow office in May 2022, in breach of the Russia (Sanctions) (EU Exit) Regulations 2019. The penalty is the first OFSI enforcement action against the legal-services sector and the first against a Big Law firm; OFSI signalled further professional-services enforcement is in the pipeline. HSF London's voluntary disclosure and full cooperation secured a 50% penalty reduction from an initial £930,000 basis.

On 24 February 2025, the third anniversary of Russia's full-scale invasion of Ukraine, the Council of the European Union adopted the 16th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/395 amending Regulation 833/2014 and a cluster of associated regulations (2025/389, 2025/390, 2025/392, 2025/398, 2025/401). The package introduces the EU's first import ban on Russian primary aluminium (CN 7601) under a 275 kt transition quota (~80% of 2024 volumes), expels 13 additional Russian banks from the SWIFT financial-messaging system, adds 74 vessels (153 total) to the shadow-fleet port-access and services ban, prohibits any temporary storage of Russian crude and petroleum products in EU ports, bans transactions with major Russian airports (Moscow Vnukovo, Zhukovsky) and ports (Astrakhan, Makhachkala, Ust-Luga, Primorsk, Novorossiysk) used for sanctions circumvention, extends flight-ban coverage to 25 third-country airlines operating domestic Russian routes, and adds 83 asset-freeze listings (48 individuals, 35 entities) under Regulation 269/2014. Parallel measures cover Belarus and the non-government-controlled areas of Ukraine. Entry into force on 25 February 2025.

Canada made SOR/2025-33, Regulations Amending the Special Economic Measures (Russia) Regulations, registered and effective 2025-02-21. The regulations add 32 individuals (Schedule 1, Part 1) and 44 entities (Schedule 1, Part 2) tied to Russia's military-industrial base, sanctions circumvention, disinformation and the forced deportation/filtration of Ukrainian children. A new Schedule 1.1 lists 109 vessels by IMO number — 92 oil tankers and 9 LNG tankers moving Russian energy exports to third countries, plus 8 vessels moving arms and related material between Russia, Iran and North Korea — banning their access to Canadian ports and waters and prohibiting dealings, asset provision and financial/other services in relation to them.

President Trump signed Executive Order 14203, "Imposing Sanctions on the International Criminal Court," on 6 February 2025, declaring a national emergency under IEEPA over the ICC's "illegitimate and baseless actions targeting America and our close ally Israel." The order authorises OFAC asset-blocking and INA § 212(f) entry suspensions against any foreign person determined by Treasury (in consultation with State) to have directly engaged in or materially assisted ICC efforts to investigate, arrest, detain, or prosecute protected persons (US persons and persons of US-allied non-ICC-state parties such as Israel). On 13 February 2025 OFAC made the first designation under the EO, adding ICC Prosecutor Karim Khan to the SDN List. OFAC subsequently codified the prohibitions into the new 31 CFR Part 528 ("International Criminal Court-Related Sanctions Regulations") published in abbreviated form on 1 July 2025 (FR doc 2025-12036). The program has since been used to designate eight additional ICC judges across 5 June 2025, 20 August 2025, and 18 December 2025 announcements.

China's Unreliable Entity List (UEL) Working Mechanism, led by MOFCOM, issued Announcement [2025] No. 2 on 4 February 2025, designating PVH Group (parent of Calvin Klein and Tommy Hilfiger) and Illumina Inc. (US genomics / gene-sequencing equipment maker) as Unreliable Entities under the 2020 UEL Provisions, citing violations of normal market-transaction principles and discriminatory measures against Chinese enterprises. PVH was cited for its Xinjiang-cotton sourcing boycott (MOFCOM probe launched September 2024); Illumina was cited for restricting Chinese customers' access to gene-sequencing equipment. The announcement was issued on the same day as China's IEEPA-retaliation tariff package (10–15 % on US coal, LNG, crude oil, agricultural goods, and autos), making it the first UEL listing of a Western consumer-brand / retail company and the first combining a UEL designation with a subsequent sector-specific export prohibition (gene sequencers, imposed 28 February 2025).

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.

HM Treasury's Office of Financial Sanctions Implementation (OFSI), with the UK Foreign Office, announced on 13 January 2025 a sanctions package targeting Russia's oil "shadow fleet" — vessels operated outside Western maritime insurance and flag-state registries to evade the G7+ Russian crude price cap (set at $60/bbl since December 2022). The package designated 18 vessels (oil tankers transporting Russian crude in violation of the cap) and traders, with separate designations of two LNG carriers and two oil-services firms. This is the largest single UK shadow-fleet designation to date and was synchronised with EU Council and US OFAC packages in mid-January 2025.

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.

China's Unreliable Entity List Working Mechanism, led by MOFCOM, issued Announcement [2025] No. 1 on 2 January 2025 designating 10 US defense entities — five Lockheed Martin subsidiaries (Missiles and Fire Control, Aeronautics, Missile System Integration Lab, Advanced Technology Laboratories, Ventures), the Javelin Joint Venture (Raytheon/Lockheed Martin), Raytheon Missile Systems, and three General Dynamics units (Ordnance and Tactical Systems, Information Technology, Mission Systems) — as Unreliable Entities under the 19 September 2020 Provisions on the Unreliable Entity List, citing their participation in US arms sales to Taiwan. The measures prohibit the 10 firms from engaging in import/export activity related to China and from making new investments in China, and bar approval/renewal of work permits and stay/residence qualifications for their senior executives. This is the first multi-entity UEL designation under the 2020 Provisions and was issued the same day as the parallel MOFCOM Announcement [2025] No. 1 of the export-control bureau adding 28 US entities to China's Export Control List — together establishing a coordinated two-track countermeasure template against US defense and dual-use industry.