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

FinCEN published a final rule on January 25, 2024 adjusting the maximum civil monetary penalties (CMPs) for Bank Secrecy Act (BSA) violations as mandated by the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended by the 2015 Improvements Act. Adjustments are calculated using the CPI-U percent change between October 2022 and October 2023 and are codified in 31 CFR § 1010.821. The update covers 12 BSA statutory penalty provisions, ranging from per-day recordkeeping violations to wilful correspondent-account and special-measures infractions, with the largest single-penalty ceiling rising to $1,731,383.

OFAC published a final rule on January 12, 2024 adjusting the maximum civil monetary penalty (CMP) ceiling amounts across five statutory authorities as mandated by the Federal Civil Penalties Inflation Adjustment Act of 1990 (as amended by the 2015 Improvements Act). The 2024 adjustment multiplier is 1.03241 (reflecting the October 2022–October 2023 CPI-U change). Penalties under IEEPA rise from $356,579 to $368,136; TWEA penalties from $105,083 to $108,489; and the Narcotics Kingpin Act maximum from $1,771,754 to $1,829,177. The rule is issued as a final rule effective on publication without prior notice and comment under the non-discretionary "good cause" exemption.

Qatar's Cabinet approved and publicly launched the Third National Development Strategy (NDS3) 2024-2030 on 10 January 2024, the final-stage framework on the path to Qatar National Vision 2030. NDS3 targets average annual GDP growth of 4%, a 25% GHG-emissions reduction, and a skilled-workforce share rising to 46% of the labour force, anchored by LNG capacity expansion from ~77 mtpa to ~142 mtpa and diversification into manufacturing, logistics, financial services, and tourism clusters. It is the parent umbrella under which all sectoral implementing strategies — including the Qatar National Manufacturing Strategy 2024-2030 — and all QIA sovereign-wealth deployment criteria operate through 2030.

Switzerland's Federal Council promulgated the Verordnung über die Mindestbesteuerung grosser Unternehmensgruppen (Mindestbesteuerungsverordnung, MindStV; French: OIMin), SR 642.161, AS 2023 841, on 22 December 2023, with effect from 1 January 2024. The ordinance enacts a 15% Qualified Domestic Minimum Top-up Tax (QDMTT — Ergänzungssteuer) on Swiss constituent entities of MNE groups with consolidated annual revenue ≥ EUR 750 million, enacted under the temporary constitutional authority granted by Swiss voters in a popular referendum on 18 June 2023 (78.5% yes, Art. 129a BV). The Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR) were deliberately deferred to subsequent ordinance amendments, targeting FY 2025 phasing. The Swiss Federal Tax Administration (ESTV / AFC) is the administering authority; first QDMTT returns and GloBE Information Returns due 30 June 2026.

FinCEN published the Beneficial Ownership Information Access and Safeguards Final Rule (FR Doc 2023-27973, 88 FR 88732, December 22, 2023; effective February 20, 2024), implementing the access and disclosure provisions of Section 6403(c) of the Corporate Transparency Act (CTA) enacted as part of the Anti-Money Laundering Act of 2020. The rule defines six categories of authorized recipients permitted to access the FinCEN BOI database — US federal agencies engaged in national security/intelligence/law enforcement, state/local/tribal law enforcement, foreign law enforcement and competent authorities (via intermediary federal agency), financial institutions using BOI for customer due diligence (CDD), federal functional regulators assessing financial-institution CDD compliance, and Treasury officers/employees. Access is to be phased in, beginning with a 2024 pilot for key federal agencies before extending to financial institutions and their supervisors. The rule establishes data-security standards, re-disclosure prohibitions, and oversight mechanisms governing each recipient category.

FinCEN published a final rule (FR Doc 2023-26399, 88 FR 83499, November 30, 2023; effective January 1, 2024) extending the initial beneficial ownership information (BOI) reporting deadline under the Corporate Transparency Act (CTA) for reporting companies created or registered in calendar year 2024. Rather than the default 30-day window, these companies receive 90 calendar days from the date of receiving actual or public notice of creation or registration becoming effective to file their initial BOI reports with FinCEN. Companies created before January 1, 2024 retain their original deadline of January 1, 2025; companies created on or after January 1, 2025 revert to the standard 30-day window.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) reached a $968,618,825 settlement with Binance Holdings, Ltd. — a Cayman Islands–domiciled virtual-currency exchange — to resolve civil liability for 1,667,153 apparent violations of multiple sanctions programs (Iran, Cuba, North Korea, Syria, and the Crimea region of Ukraine) committed between August 2017 and October 2022. OFAC determined the apparent violations were not voluntarily self-disclosed and that Binance's conduct was egregious; the settlement requires a five-year independent compliance monitor and was announced concurrently with parallel DOJ, FinCEN, and CFTC resolutions totaling approximately $4.3 billion in aggregate (including criminal forfeiture and BSA/AML penalties), alongside a separate criminal plea by founder Changpeng Zhao. The settlement is the largest civil monetary penalty in OFAC's history.

FinCEN published a final rule (FR Doc 2023-24559, 88 FR 76995, November 8, 2023; effective January 1, 2024) specifying when and how entities required to report beneficial ownership information (BOI) under the Corporate Transparency Act (CTA) may use another entity's FinCEN identifier in lieu of disclosing the underlying individual beneficial owners. A reporting company may substitute a related entity's FinCEN ID when: (1) that entity has obtained a FinCEN identifier and provided it to the reporting company, (2) the individual is a beneficial owner solely through an ownership interest in the other entity, and (3) the beneficial owners of both entities are the same. Any change to beneficial ownership of the other entity requires an updated BOI report, after which the entity FinCEN identifier may no longer be used until recertified.

Saudi Arabia's Personal Data Protection Law (PDPL), issued under Royal Decree M/19 (16 September 2021) and substantively amended by Royal Decree M/148 (27 March 2023), entered into force on 14 September 2023 with a one-year transition period that ended on 14 September 2024 — at which point the Saudi Data & Artificial Intelligence Authority (SDAIA) became the binding regulator with full enforcement powers. Alongside the Implementing Regulations and the Regulations on the Transfer of Personal Data Outside the Kingdom (both issued 7 September 2023), SDAIA published in 2024 a set of four pre-approved Standard Contractual Clauses templates (C2C, C2P, P2P, P2C) governing cross-border transfers. The regime establishes consent requirements, DPO appointment, a 72-hour breach notification duty, and prior-clearance / SCC-or-BCR-style conditions on personal-data exports out of Saudi Arabia.

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.

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.

OFAC replaced the abbreviated July 2014 South Sudan Sanctions Regulations (31 CFR Part 558) with a comprehensive final rule that adds interpretive guidance, definitions, and general licenses while implementing the full set of prohibitions in Executive Order 13664 of April 3, 2014. The rule does not expand the underlying blocking authority or add new designations; it codifies the existing program in a complete regulatory framework accessible to the public and regulated community. Target: persons threatening South Sudan's peace, security, or stability, obstructing the Comprehensive Peace Agreement, or responsible for human rights abuses or conflict-mineral trade that finances armed groups.

On 24 February 2023 the US Treasury Department's Office of Foreign Assets Control (OFAC) announced sanctions on 22 individuals and 83 entities, which Treasury describes as targeting key sectors, evasion efforts and military supplies. Treasury issued a determination under Executive Order 14024 identifying the metals and mining sector of the Russian Federation economy as a sector subject to sanctions, and designated 11 Russian financial institutions, including Credit Bank of Moscow, plus Russian defence and advanced-materials enterprises and third-country evasion facilitators. General Licenses 60 and 61 authorise wind-down of dealings with newly blocked entities through 25 May 2023.

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.

FinCEN published a final rule on January 19, 2023 (88 FR 3312) adjusting the maximum civil monetary penalties for Bank Secrecy Act (BSA) violations under 31 CFR § 1010.821, as mandated by the Federal Civil Penalties Inflation Adjustment Act of 1990 (as amended by the 2015 Improvements Act). The 2023 multiplier is 1.07745, reflecting the October 2021 → October 2022 CPI-U change per OMB Memorandum M-23-05. A correction notice (88 FR 7357, Feb. 3, 2023) revised certain table entries; the corrected amounts are authoritative and are reflected in this filing. The table covers 10 BSA statutory penalty provisions, with the largest single-penalty ceiling rising to $1,677,030.

FinCEN issued an order on 18 January 2023, published in the Federal Register on 23 January 2023 (FR Doc 2023-01189), prohibiting US covered financial institutions from transmitting funds to, from, or through Bitzlato Limited, a virtual-currency exchange incorporated in Hong Kong and identified as a primary money-laundering concern in connection with Russian illicit finance. The order invokes Section 9714(a) of the Combating Russian Money Laundering Act, as amended by Section 6106 of the National Defense Authorization Act for Fiscal Year 2022 (31 U.S.C. 5323). The action was coordinated with a DOJ criminal arrest of Bitzlato co-founder Anatoly Legkodymov and a parallel Europol/Eurojust-supported disruption of Bitzlato's infrastructure, effective 18 January 2023.

OFAC published a final rule on January 13, 2023 adjusting the maximum civil monetary penalty (CMP) ceiling amounts across multiple statutory sanctions authorities as mandated by the Federal Civil Penalties Inflation Adjustment Act of 1990 (as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015). The adjustment covers IEEPA, TWEA, and the Narcotics Kingpin Act authorities, resetting the penalty ceilings that apply to violations adjudicated through 2023. A correction notice (C1-2023-00593, April 17, 2023) fixed a purely typographical error in Appendix A to 31 CFR Part 501 — paragraph numbering "v" corrected to "vi" — with no change to any penalty amount.

On 21 December 2022 OFAC published final rule FR Doc 2022-27564, amending 30 CFR parts (31 CFR Parts 510, 525, 536, 539, 541, 542, 544, 546, 547, 548, 549, 551, 552, 555, 558, 560, 561, 562, 569, 576, 579, 582, 583, 584, 585, 591, 594, 596, 597, 598) to add or update general licenses authorising (1) official business of the US government and (2) official business of designated international organisations and entities across the full OFAC program library. The rule also updates the 50 Percent Rule interpretive provision, clarifying that an entity's property is blocked when one or more blocked persons own an aggregate interest of 50 percent or more — directly or indirectly — and corrects CFR citations to meet current Federal Register formatting requirements. Published as companion to FR Doc 2022-27639 (NGO and humanitarian GLs), both rules effective 21 December 2022.

OFAC published an interim final rule creating 31 CFR Part 599 to implement Executive Order 14059 (December 15, 2021), which declared a national emergency regarding the unusual and extraordinary threat posed by the global illicit drug trade, including fentanyl and synthetic opioid trafficking. The regulations establish blocking prohibitions, SDN List designation procedures, and enforcement mechanisms targeting foreign persons who materially contribute to international drug proliferation. OFAC stated it would supplement this interim rule with more comprehensive final regulations covering licensing, reporting, and penalty procedures.

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.

On 16 October 2022, Jordan promulgated Investment Environment Law No. 21 of 2022, published in Official Gazette No. 5821, entering into force 90 days later on approximately 14 January 2023. The law replaces the 2014 Investment Law No. 30 and restructures Jordan's entire FDI-promotion architecture: it establishes the Ministry of Investment (MOIN) and the Investment Council as apex bodies, codifies Development Zones, Free Zones, and Special Economic Zones (including the Aqaba Special Economic Zone — gateway for Jordan's phosphate exports via JPMC, the world's second-largest phosphate producer), and enshrines national-treatment guarantees with customs exemptions, zero-rated sales tax incentives, and investor-state dispute-settlement provisions for qualifying protected FDI. The law is the foundational parent statute for Jordan's IMF Extended Fund Facility-conditioned reform agenda and positions the country within the IMEC (India–Middle East–Europe Corridor) trade-investment integration architecture.

FinCEN issued a final rule (87 FR 59498, September 30, 2022) implementing the Corporate Transparency Act (CTA) by requiring most corporations, limited liability companies, and similar entities created in or registered to do business in the United States to file beneficial ownership information (BOI) reports with FinCEN. Reporting companies must identify two categories of individuals: beneficial owners (persons exercising substantial control or owning ≥25% of the entity) and company applicants (persons who filed the formation documents). Entities formed before January 1, 2024 had until January 1, 2025 to file; entities formed on or after that date had 30 days. Non-compliance carries civil penalties of up to $500/day and criminal penalties of up to $10,000 and two years imprisonment.

OFAC reissued the Cyber-Related Sanctions Regulations (31 CFR Part 578) in their entirety on 6 September 2022, replacing the abbreviated placeholder framework first published on 31 December 2015. The reissuance implements Executive Order 13694 (1 April 2015, blocking property of persons engaging in significant malicious cyber-enabled activities) and Executive Order 13757 (28 December 2016, expanding that authority to include election interference). The full-form regulations add interpretive definitions, general licences, and civil-penalties provisions — providing compliance clarity for US financial institutions and technology companies without expanding the underlying sanctions perimeter.

On 13 July 2022 OFAC formally published in the Federal Register two general licenses (GL 2 and GL 10) that had been issued under the Ukraine-/Russia-Related Sanctions program and made available previously only on OFAC's website. Both licenses had already expired by the time of publication: GL 2 (EO 13662 Directive 4 wind-down, expired September 2014) authorised a limited window to wind down contracts involving Russian energy-sector entities subject to sectoral sanctions, while GL 10 (EO 13685 Crimea, expired October 2016) authorised divestiture of holdings in blocked Russian infrastructure entity PJSC Mostotrest. The Federal Register codification is an administrative archival step with no substantive change to the sanctions regime.

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.

OFAC adopted a final rule on 1 July 2022 amending the Global Terrorism Sanctions Regulations (GTSR, 31 CFR Part 594) to implement Executive Order 13886 ("Modernizing Sanctions To Combat Terrorism," 9 September 2019). The rule expands the designation criteria in §594.201 to reflect EO 13886's additions, allowing OFAC to block property of foreign persons who act on behalf of, or provide material support to, foreign terrorist organizations (FTOs) — broadening the perimeter beyond EO 13224's original focus on persons threatening international peace and stability through terrorism. Supporting amendments update cross-references and the definition of "effective date" throughout Part 594 to reflect the new authority baseline.

The Council of the EU adopted Council Implementing Regulation (EU) 2022/878 of 3 June 2022, implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. The regulation adds 65 individuals and 18 legal entities to Annex I, subjecting them to an EU-wide asset freeze and a prohibition on EU persons or entities making funds or economic resources available to them. The listed entities span Russia's defense-industrial base, military-linked vehicle and tyre manufacturing, and financial-market infrastructure.

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.

OFAC final rule (FR Doc 2022-12445, 87 FR 35068) amending the Cuban Assets Control Regulations at 31 CFR Part 515 to implement elements of the Biden administration's May 16, 2022 Cuba policy announcement supporting the Cuban people. The rule reinstates the group people-to-people educational travel general license (suspended under the Trump administration) for organizations sponsoring exchanges that promote meaningful contact with Cubans and support civil society; removes the $1,000 quarterly limit on family remittances to close relatives in Cuba; authorizes donative remittances to Cuban nationals not affiliated with the government or Communist Party; and expands authorizations for professional meetings and conferences in Cuba. Effective June 9, 2022.

On 2 May 2022 OFAC published a comprehensive final rule in the Federal Register renaming the Ukraine Related Sanctions Regulations (31 CFR Part 589) to the Ukraine-/Russia-Related Sanctions Regulations and replacing the abbreviated regulatory text that had been in place since 2014 with a fully elaborated framework. The new Part 589 incorporates interpretive guidance, definitional provisions, and consolidated general licenses implementing Executive Orders 13660, 13661, and 13662 — the original March 2014 Ukraine/Crimea-crisis authorities. The rule does not introduce new substantive prohibitions; it formalises and makes accessible the regulatory infrastructure that underlies subsequent GL issuances (e.g., GL 13Q/13R, GL 15K/15L) and OFAC designation actions under the Ukraine-/Russia-Related Sanctions program.

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 16 March 2022 the Swiss Federal Council adopted a total revision of the Ordinance on Measures against Belarus (SR 946.231.116.9), aligning Switzerland's autonomous sanctions with the EU's Belarus regime. It bans imports of Belarusian petroleum products, potassium chloride ("potash"), wood, iron and steel, and cement and rubber products; bans exports of goods used to manufacture or process tobacco products, weapons, surveillance equipment, and goods usable for Belarus's military or security development; and imposes financial sanctions including a ban on public financing for trade with or investment in Belarus, restrictions on securities/loans/ deposits, a prohibition on transactions with the National Bank of the Republic of Belarus, and exclusion of listed Belarusian banks from SWIFT. The ordinance entered into force on the day it was adopted.

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.

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 28 February 2022, South Korea's government condemned Russia's invasion of Ukraine and announced it would strengthen export control review to block strategic items -- microelectronics, telecommunications equipment, sensors, navigation equipment, avionics, marine equipment, and aircraft components -- from reaching Russia. The statement also committed Korea to joining the exclusion of designated Russian banks from the SWIFT international payments system, with implementation details to follow through interagency consultation, alongside plans to release strategic petroleum reserves and divert LNG cargoes to Europe.

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.

OFAC published a final rule on February 9, 2022 adjusting the maximum civil monetary penalty (CMP) ceiling amounts across multiple statutory sanctions authorities as mandated by the Federal Civil Penalties Inflation Adjustment Act of 1990 (as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015). The 2022 adjustment reflects the October 2020 to October 2021 CPI-U change (approximately 6.2%), raising the IEEPA ceiling from $311,562 to $330,947, the TWEA ceiling from $91,816 to $97,529, and the Narcotics Kingpin Act maximum from $1,548,075 to $1,644,396. The rule is issued as a final rule effective on publication without prior notice and comment under the non-discretionary "good cause" exemption.

FinCEN published a final rule on January 24, 2022 (87 FR 3729) adjusting the maximum civil monetary penalties (CMPs) for Bank Secrecy Act (BSA) violations under 31 CFR § 1010.821, as mandated by the Federal Civil Penalties Inflation Adjustment Act of 1990 (as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015). The 2022 multiplier is 1.06222, reflecting the October 2020 → October 2021 CPI-U change per OMB Memorandum M-22-07 of December 15, 2021 — the same unusually large ~6.2% inflationary adjustment applied across all federal agency CMP schedules that cycle. The largest single-penalty ceiling rises to $1,556,481 (due-diligence and special-measures violations under 31 U.S.C. § 5321(a)(7)).

FinCEN amended 31 CFR Part 1010 to remove civil penalty language that had become obsolete following the American Jobs Creation Act of 2004 (AJCA). The AJCA restructured FBAR (Report of Foreign Bank and Financial Accounts) penalties, raising the maximum for willful violations beyond what the pre-existing regulation text authorised, creating an inconsistency between statute and regulation. The final rule is administrative in nature: it deletes superseded penalty provisions and aligns regulatory text with the statutory penalty structure already in force since 2004, imposing no new obligations on FBAR filers.

FinCEN issued a final rule (86 FR 62914, effective 15 November 2021) amending 31 CFR 1010.370 to align its Geographic Targeting Order (GTO) regulations with statutory amendments to 31 U.S.C. 5326 (Bank Secrecy Act). The principal change extends GTO authority to cover nonfinancial trades or businesses in addition to domestic financial institutions — broadening the pool of entities that FinCEN can subject to heightened transaction-reporting and recordkeeping requirements in a designated geographic area. The rule also updates the notification procedure (directing GTOs to chief executive officers) to conform to the amended statute. No new GTO was issued by this rule; it is a framework update enabling future GTO issuance to a wider class of obligees.

The Bahraini Council of Ministers, chaired by HRH Crown Prince and Prime Minister Prince Salman bin Hamad Al Khalifa and issued pursuant to directives of HM King Hamad bin Isa Al Khalifa, launched the five-pillar Economic Recovery Plan on 31 October 2021 as the government's post-COVID-19 structural-adjustment and growth framework through 2024–2030. The plan catalyses a USD 30 billion strategic-projects pipeline, delivers six new priority-sector strategies (oil and gas, tourism, logistics, financial services, telecommunications/ICT, manufacturing), targets 20,000 new Bahraini jobs and 10,000 annual training slots, and mandates fiscal balance by 2024 including the doubling of VAT from 5% to 10% effective 1 January 2022 under Royal Decree 33/2021. It is the foundational parent framework for all subsequent Bahraini sectoral decrees and investment decisions through 2030, and is materially relevant to the global non-Chinese aluminium supply chain through Aluminium Bahrain (Alba), one of the world's largest non-Chinese primary aluminium smelters at approximately 1.5 million tonnes per annum.

The Personal Information Protection Law of the People's Republic of China (中华人民共和国个人信息保护法 — PIPL) was adopted at the 30th meeting of the 13th NPC Standing Committee on 20 August 2021 and entered into force on 1 November 2021, constituting the third and final pillar of China's cybersecurity and data-governance regulatory trinity alongside the Cybersecurity Law (2016) and the Data Security Law (2021). The PIPL is China's comprehensive personal-information statute establishing consent-based and necessity-based legal bases for PI processing, a tiered cross-border personal-data transfer regime (CAC security assessment / PI protection certification / Standard Contractual Clauses), extraterritorial application (Art. 3) to non-Chinese controllers offering services to or analysing the behaviour of PRC residents, and a heightened protection regime for sensitive personal information and data of minors under 14. It mandates data-protection impact assessments, personal-information-protection-officer obligations at designated handlers, breach notification, and a full suite of data-subject rights including access, rectification, deletion, portability, objection, and automated- decision-making opt-out. Article 53 requires overseas controllers to establish a domestic representative or designated entity in China, providing a domestic enforcement counterparty.

The Data Security Law of the People's Republic of China (中华人民共和国数据安全法) was adopted at the 29th meeting of the 13th NPC Standing Committee on 10 June 2021 and entered into force on 1 September 2021, constituting the second pillar of China's cybersecurity and data-governance regulatory trinity alongside the Cybersecurity Law (2016) and the Personal Information Protection Law (2021). The DSL establishes a tiered data-classification regime — "important data" and "national core data" — with escalating security obligations including risk assessment, risk monitoring, breach reporting, and classified-protection requirements for data handlers. It introduces a data-export security review for "important data" generated or collected within China, the statutory parent authority operationalised by the 2024 CAC Cross-Border Data Flow Provisions, and enacts a §36 blocking statute prohibiting Chinese organisations and individuals from transferring data stored in China to foreign judicial or law-enforcement authorities without prior PRC government approval.

OFAC published a final rule on March 17, 2021 (86 FR 14534) adjusting the maximum civil monetary penalty (CMP) ceiling amounts across multiple statutory sanctions authorities as mandated by the Federal Civil Penalties Inflation Adjustment Act of 1990 (as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015). The 2021 adjustment reflects the October 2019 to October 2020 CPI-U change (approximately 1.2%, reflecting COVID-suppressed inflation), raising the IEEPA ceiling from $307,922 to $311,562, the TWEA ceiling from $90,743 to $91,816, and the FNKDA maximum from $1,529,991 to $1,548,075. The rule is issued as a final rule effective on publication without prior notice and comment under the non-discretionary "good cause" exemption.

The US Department of the Treasury's Office of Foreign Assets Control (OFAC) published abbreviated Hong Kong-Related Sanctions Regulations at 31 CFR Part 585, codifying the sanctions framework established by Executive Order 13936 of July 14, 2020 ("The President's Executive Order on Hong Kong Normalization"). The regulations prohibit all transactions with persons designated under EO 13936 — those determined to have undermined Hong Kong's autonomy or contributed to the erosion of freedoms guaranteed under the Sino-British Joint Declaration — and add designated persons to the OFAC Specially Designated Nationals (SDN) list. OFAC published the rules in abbreviated form for immediate public guidance, with intent to supplement with full interpretive guidance, general licenses, and licensing policy.

The US Treasury's Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR) to exclude entities and sub-entities identified on the Cuba Restricted List from three remittance general licences: §515.570 (outbound remittances), §515.572(a)(3) (remittance forwarding services), and §515.587 (other authorised remittances). The rule additionally amended the ordinarily-incident provision §515.421 to confirm that transactions routed through Cuba Restricted List entities are not covered even where the underlying licence does not expressly exclude them. The effective date was 30 days after Federal Register publication, on 26 November 2020.

On 8 October 2020, the US Treasury's Office of Foreign Assets Control (OFAC) determined that section 1(a)(i) of Executive Order 13902 (10 January 2020) applies to the financial sector of the Iranian economy, exposing non-US persons that operate in or knowingly facilitate significant transactions with that sector to secondary sanctions. Concurrently, OFAC designated eighteen Iranian banks (sixteen under E.O. 13902, one as an owned-or-controlled affiliate, and Hekmat Iranian Bank under E.O. 13382 non-proliferation authority). After a 45-day wind-down, the secondary-sanctions exposure became effective on 22 November 2020. The determination was formally republished in the Federal Register on 1 October 2025 (FR Doc 2025-19123) under Trump 2.0's maximum-pressure restoration; the underlying economic measure dates to the 2020 action.

OFAC published an interim final rule on September 3, 2020 (85 FR 54909; FR_DOC 2020-19237) adjusting civil monetary penalty (CMP) ceiling amounts for recordkeeping and reporting violations under 31 CFR Part 501, effective October 5, 2020. The adjustment is a catch-up correction: recordkeeping/reporting CMPs were inadvertently omitted from the August 1, 2016 initial catch-up adjustment mandated by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (Pub. L. 114-74 § 701). The rule raises the late-filing penalty from $5,000 to $5,942 (per occurrence), the blocked-assets late-filing recurring penalty from $1,000 to $1,189 (per 30-day period), and the failure-to-maintain-records maximum from $50,000 to $59,522.

Qatar's Amir Sheikh Tamim bin Hamad Al Thani promulgated Law No. (1) of 2019 on 7 January 2019, replacing Law No. 13 of 2000 and authorising non-Qatari investors to hold up to 100% equity in Qatari enterprises across all economic sectors, subject to executive regulations. The law provides national-treatment guarantees, protects against expropriation except for public purpose with fair compensation, and permits full repatriation of investment income and capital. Banking, insurance, and commercial agencies remain subject to sector-specific ownership caps unless exempted by the Council of Ministers.