Industrial Policy & Trade Monitor· 2662 actions· ✨ 89 recent

The Council of the EU adopted Implementing Regulation (EU) 2026/262, implementing Regulation (EU) 2023/1529 concerning restrictive measures in view of Iran's military support to Russia's war of aggression against Ukraine. The listing adds 4 individuals and 6 entities to the EU asset freeze, bringing the total under this regime to 24 individuals and 26 entities. Newly listed entities include Fanavaran Sanat Ertebatat Company and front-company trader Sahara Thunder (UAV electronic components and guidance systems), and Shahid Bagheri Industrial Group, Khojir Missile Development and Production, and procurement firm Pishgaman Tejarat Rafi Novin Co. (ballistic missile manufacturing and propellant-precursor procurement). All funds and economic resources of the listed parties are frozen within the EU, and EU persons/entities are barred from making funds available to them.

BIS issued an Interim Final Rule (IFR) on 21 January 2026 (effective 20 January 2026) easing Export Administration Regulations (EAR) controls on certain civil unmanned aerial vehicles (UAVs) and related technology. The IFR makes two changes: (i) ECCN 9A012.a.1 commercial UAVs with maximum endurance under one hour can now be exported License-Free (NLR) to most Wassenaar Arrangement Participating States (Country Group A:1, excluding Malta, Russia, Ukraine), versus the prior limitation to UK / Australia / Canada only; and (ii) License Exception STA (Strategic Trade Authorization) is expanded to cover certain MT-controlled UAVs that cannot deliver a 500kg payload to 300+ km — including long-range cargo-delivery drones and ECCN 9A120 agricultural-spraying UAVs — for export to Country Group A:5 partners and allies. The IFR implements the export-promotion directive in §6 of EO 14307 (Unleashing American Drone Dominance, 6 June 2025). Comment period closes 19 February 2026.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) designated 10 individuals and entities in Venezuela and Iran on 30 December 2025 for facilitating Iran's proliferation of unmanned aerial vehicles (UAVs) and ballistic-missile inputs. Venezuela-based Empresa Aeronautica Nacional SA (EANSA) and its chair, Jose Jesus Urdaneta Gonzalez, were designated for negotiating directly with Iran's Qods Aviation Industries (QAI) and overseeing local assembly of QAI's Mohajer-series UAVs, re-branded in Venezuela as the ANSU series — an arrangement OFAC states has run since 2006. Separately, three Iran-based persons were designated for procuring sodium perchlorate, sebacic acid and nitrocellulose — precursor chemicals for ballistic-missile propellant and warhead production — on behalf of Parchin Chemical Industries (PCI), a unit of Iran's Defense Industries Organization (DIO). The action was taken under Executive Order 13382 (WMD proliferators and supporters) and Executive Order 13949 (Iran conventional-arms activities), in furtherance of National Security Presidential Memorandum 2.

Ukraine's President signed Decree No. 871/2025 on 29 November 2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against a list of Russian legal entities and individuals identified by the Security Service of Ukraine (SBU) as involved in the production, supply, or operational support of unmanned aerial vehicles (UAVs/drones) used by Russia. The decree imposes asset freezes and restrictions on commercial transactions and investment instruments with the designated parties. It entered into force on 2 December 2025, the date of official publication.

The US Treasury's Office of Foreign Assets Control designated 32 individuals and entities based in Iran, the UAE, Turkiye, China, Hong Kong, India, Germany and Ukraine for operating procurement networks that supply Iran's ballistic missile and UAV programmes, including missile propellant precursors and UAV components. The action is Treasury's second round of nonproliferation sanctions since the 27 September 2025 reimposition of UN sanctions on Iran ("snapback") over its non-compliance with international nuclear and missile commitments. Designated entities include Iran-based Kimia Part Sivan Company (KIPAS), which Treasury says has worked with the IRGC-Qods Force to advance Iran's UAV programme. All property and interests of the designated parties subject to US jurisdiction are blocked, and US persons are generally prohibited from transacting with them.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to add 29 entries — 26 entities and 3 addresses — to the Entity List under the destinations of China (19), Turkey (9), and the United Arab Emirates (1). BIS determined these parties were diverting US-origin items to Iran, including to parties already on the BIS Entity List and on OFAC's Specially Designated Nationals (SDN) List, in support of Iranian drone-parts and electronics-procurement networks. The rule is a final rule effective October 8, 2025; new license requirements apply to all items subject to the EAR for these listed parties under a presumption-of-denial review policy.

On 16 August 2025, Ukraine's President signed Decree No. 599/2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 39 individuals and 55 legal entities identified as involved in developing, manufacturing, or supplying components for Russian unmanned aerial vehicles (UAVs) with artificial-intelligence elements. The list covers 43 Russian entities (including drone makers Prognatik, Rozumni Ptakhy, Zala Aero, and KB Vostok, plus AI research centres Neurolab and TsBST), 10 Chinese suppliers of navigation receivers, engines, cameras, and microchips (including Dongguan Standard Trading, Zhejiang Lianxing Machinery, Shenzhen Sky Bow Navigation Technology, and Topscom Precision Industry), and 2 Belarusian component suppliers. Sanctions impose asset freezes and restrictions on commercial transactions and investment instruments, entered into force immediately upon signature and revocable no later than 15 August 2035.

Federal Law No. 297-FZ, adopted 31 July 2025, amends Article 150 of the Russian Tax Code to add a new exemption (clause 23) from import VAT for engines, spare parts and components imported into Russia for the construction, repair or modernization of civilian unmanned aerial vehicles with a maximum take-off weight between 0.15 and 30 kg. The exemption also covers printed technical publications and prototype components necessary for developing or testing such UAVs and their engines. The measure takes effect 1 October 2025 and is intended to lower input costs for Russia's domestic civilian-drone manufacturing base, which has scaled up sharply since 2022 alongside the country's military UAV program.

The US Treasury's Office of Foreign Assets Control designated five entities and one individual based in Iran, Hong Kong, Taiwan and China for procuring CNC (computer numerical control) machine tools on behalf of Iran Aircraft Manufacturing Industrial Company (HESA), the state-owned defense-ministry subsidiary that builds Iran's Ababil-series military UAVs used by the IRGC. Designated parties include Javad Alizadeh Hoshyar, CEO of Iran-based Control Afzar Tabriz Co Ltd, which used Hong Kong-based Clifton Trading Limited as an intermediary to obscure CNC-machine shipments to HESA, and Taiwan-based Mecatron Machinery Co Ltd and Joemars Machinery and Electric Industrial Co Ltd, which shipped CNC machines toward Iran through similar concealment channels. The action was taken pursuant to National Security Presidential Memorandum 2 (NSPM-2), which directs that Iran be denied conventional and asymmetric weapons capabilities. All designated parties' US property and interests are blocked and US persons are generally barred from transacting with them.

On 18 July 2025 the Council of the European Union adopted Council Implementing Regulation (EU) 2025/1469, implementing Article 8a(1) of Regulation (EC) No 765/2006, adding eight Belarusian entities to the Annex I asset-freeze list for supporting Belarus's military-industrial complex. The listed entities — State-owned Foreign Trade Unitary Enterprise Belvneshpromservice, OKB TSP Scientific Production LLC, KB Unmanned Helicopters (UAVHeli), Legmash Plant OJSC, Research and Production Unitary Enterprise "Scientific and Technical Center 'LEMT' BelOMO", Laser Devices and Technologies LLC, JSC Vistan, and Rukhservomotor LLC — span defence-export trading, artillery-shell and MLRS-rocket manufacture, unmanned military aircraft, optical weapon sights, and dual-use CNC machine tools supplied to Russian defence-related enterprises. Funds and economic resources belonging to the listed entities are frozen within the EU and the EU prohibition on making resources available to them applies with effect from 19 July 2025 (date of publication in the Official Journal). The listing was adopted the same day as the EU's 18th Russia sanctions package, as a parallel complementary measure under the separate Belarus sanctions regime.

On 20 June 2025, the US Treasury's Office of Foreign Assets Control designated one individual, eight entities, and one vessel pursuant to Executive Order 13382 (WMD proliferators) for procuring and transshipping sensitive machinery to Iran's Rayan Roshd Afzar Company (RRA), a producer of UAV components and aerospace software for the IRGC. The vessel SHUN KAI XING, owned by Hong Kong-based Unico Shipping Co Ltd and chartered by Singapore-based V-Shipping Pte Ltd, was carrying the machinery for RRA and an affiliated firm when its cargo was inspected; the designated network — including China-based Shenzhen Xinxin Shipping, Dongguan Zanyin Machinery and Equipment, Athena Shipping, shipmaster Zhang Yanbing, and Turkiye-based Edisa Dis Ticaret Limited Sirketi — then falsified bills of lading to obscure the Iran-bound, RRA-consigned cargo after the inspection.

In its first major export-regulatory action of the second Trump administration, BIS amended the EAR to add 70 entities to the Entity List under the destinations of China (42), Iran (2), Pakistan (19), South Africa (3), and the United Arab Emirates (4), and modified four existing entries (France, Iran, Senegal, UK). New listings carry a license requirement for all items subject to the EAR with a presumption-of-denial review policy and no license exceptions available. Stated objectives include restricting China's acquisition of high-performance computing and quantum technologies for military use, impeding hypersonic-weapons development, disrupting Iran's UAV and defense procurement, and impairing Pakistan's unsafeguarded nuclear and ballistic-missile programs. The rule also targets the Test Flying Academy of South Africa for using U.S.-origin items to train Chinese military pilots.

Council Regulation (EU) 2024/2897 of 18 November 2024 amends Regulation (EU) 2023/1529 (restrictive measures over Iran's military support to Russia's war against Ukraine and to armed groups in the Middle East and Red Sea region). It replaces Annex II with an expanded list of goods and technology whose sale, supply or export to Iran is prohibited where they could enable UAV or missile production, across ten technology categories, and adds Article 2a, a prohibition on transactions with the ports listed in Annex IV (Amirabad and Anzali). It entered into force on publication in the Official Journal.

Bureau of Industry and Security final rule (89 FR 84460, Doc 2024-24562) adding 26 entities to the Entity List across four destinations: six in China (aviation simulation for PLA modernisation; procurement for Iran WMD/UAV programs; evasive conduct), one in Egypt and three in the UAE (acquiring US civil aircraft parts for Russian buyers post-Ukraine invasion), and sixteen in Pakistan (nine front companies of Advanced Engineering Research Organization for Pakistan's cruise-missile and strategic-UAV programs, plus seven contributing to Pakistan's ballistic- missile program). The rule also removes two existing entries. All additions are licensed under a presumption-of-denial policy for all EAR-subject items.

The Council of the EU adopted Implementing Regulation (EU) 2024/2697, implementing Regulation (EU) 2023/1529 concerning restrictive measures in view of Iran's military support to Russia's war of aggression against Ukraine. The listing adds 7 individuals and 7 legal entities to the EU asset freeze. The entities include three Iranian state and private airlines (Saha Airlines, Mahan Air, Iran Air) named as repeat carriers of Iranian-made UAVs and related technology to Russia, a UAV-procurement network (Basamad Electronic Pouya Engineering Co., Teyf Tadbir Engineering Company) run through EU-listed businessman Hossein Hatefi Ardakani, and two entities tied to Iran's ballistic-missile programme: Iran Alumina Company (IAC), Iran's sole producer of alumina powder used in solid rocket-fuel propellant, and Shahid Haj Ali Movahed Research Center, a missile R&D subsidiary of the EU-listed Shahid Hemmat Industries Group. All funds and economic resources of the listed parties are frozen within the EU, and EU persons/entities are barred from making funds available to them.

The U.S. Bureau of Industry and Security (BIS) published a final rule expanding the scope of the Iran Foreign Direct Product (FDP) rule in the Export Administration Regulations (EAR) to implement the "No Technology for Terror Act" (Public Law 118-50, Division N), signed by President Biden on April 24, 2024. The expanded rule extends EAR jurisdiction to additional foreign-produced items destined for Iran — including a broader set of items derived from U.S.-origin technology or software, or produced by plants/components that are themselves direct products of U.S.-origin technology — and requires a BIS license for their export, reexport, or in-country transfer to Iran. The rule also provides specified exclusions from the otherwise-applicable license requirements. The rule became effective on July 23, 2024 (publication July 26, 2024).

The Bureau of Industry and Security (BIS) issued a final rule (FR Doc 2024-08622; Docket 240417-0112; 89 FR 30119) amending the Export Administration Regulations (EAR) to expand the product scope of two Foreign Direct Product (FDP) rules — the Iran FDP rule and the Russia/Belarus/Temporarily occupied Crimea region of Ukraine FDP rule in 15 CFR 734.9(f) — to cover the entirety of the Common High Priority List (CHPL), an HTS-6 list developed jointly with the EU, Japan and the UK that identifies items used in Russian weapons production. The CHPL scope adds basic commercial-grade microelectronics (integrated circuits, RF transceiver modules), test/manufacturing equipment for electronic components, and CNC machine tools to the perimeter, requiring a BIS licence when these foreign-produced items are exported, reexported or transferred to Iran, Russia, Belarus or occupied Crimea. The rule was issued in response to Iran's 13 April 2024 attack on Israel and Iran's ongoing military support for the Russian war in Ukraine; it became effective 18 April 2024 (Federal Register publication 22 April 2024) with a transit grace period for in-flight shipments until 20 May 2024.

The US Bureau of Industry and Security (BIS) final rule (89 FR 25503; FR Doc 2024-07760) added 11 entries to the Entity List under China (6), Russia (3), and the United Arab Emirates (2), effective 2024-04-11. The primary rationale for the Russia and UAE tranches — and at least one China entity (Shenzhen Jiasibo Technology) — is procurement of US-controlled dual-use aerospace and UAV components for Iran's Shahed- series UAV programme via the Iran Aircraft Manufacturing Industrial Company (HESA); those drones have been used against oil tankers in the Middle East and deployed by Russia in Ukraine. The remaining five China entities were designated for acquiring US-origin items to support China's military modernisation. The rule also adds one alias to the existing entry for Shanghai Biren Intelligent Technology Co., Ltd. This action was the first Entity List final rule published after BIS implemented the 50 Percent Rule for controlling foreign subsidiaries of listed entities.

The Aizsardzības industrijas likums (Defence Industry Law), adopted by the Saeima on 27 March 2024 and published in Latvijas Vēstnesis No. 70 on 10 April 2024, is Latvia's first standalone statute codifying state-support instruments for domestically registered defence-industrial-base firms. The law establishes a strategic-partnership agreement framework between the Ministry of Defence and Latvian-registered defence-tech manufacturers (including the Latvian drone-tech cluster — Atlas Aerospace, UAV Factory, Edge Autonomy Latvia), defines continuity-of-operations and supply-security obligations for strategic-partner firms, and provides a procurement-preference channel for Latvian-registered defence suppliers in MoD and State Defence Logistics and Procurement Centre contracting. The law also streamlines export-licence processing for qualified Latvian strategic- goods exporters and aligns state-support measures with EU Treaty Article 346 defence-exemption and EU European Defence Fund / EDIRPA co-financing rules.

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) added 42 entities under 44 entries to the Entity List, effective December 7, 2023. The majority — 28 entities in Russia — are sanctioned for procuring or contracting on behalf of Russia's defense sector, including avionics, military-grade drones, and military electronics. Fourteen additional entities across Armenia, Belarus, Belgium, Cyprus, Germany, Kazakhstan, the Netherlands, China, and the UAE were added for operating diversion and transshipment networks that supply U.S.-origin items to Russian military end-users. All listed entities face a license requirement for all EAR-controlled items with a presumption of denial.

The Bureau of Industry and Security (BIS) added thirteen entities to the Entity List effective November 2, 2023 — twelve in Russia and one in Uzbekistan — for posing a significant risk of supporting Russia's war against Ukraine through the procurement, development, and proliferation of unmanned aerial vehicles (UAVs). The designated group includes ZALA Aero Group, the Kalashnikov Concern-linked maker of the Lancet loitering munition and Orlan-10 reconnaissance drone. A license requirement now applies to all items subject to the EAR exported, reexported, or transferred to these parties, with a license review policy of denial for everything except food and medicine designated EAR99 (case-by-case), and the Russia/Belarus Military End User Foreign Direct Product rule applies.

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.

The Bureau of Industry and Security (BIS) issued a final rule on 19 May 2023 strengthening existing Export Administration Regulations (EAR) sanctions against Russia and Belarus. The rule expands the Foreign Direct Product (FDP) rule — which applies EAR jurisdiction to foreign-made items produced with US technology or equipment — to cover the temporarily occupied Crimea region of Ukraine. It also revises controls targeting Iran's supply of unmanned aerial vehicles (UAVs) to Russia, closing loopholes identified in prior rounds of Russia-Ukraine-related export-control rulemaking.

The Bureau of Industry and Security (BIS) established a new Iran Foreign Direct Product (FDP) rule and created Supplement No. 7 to Part 746 of the EAR, effective 24 February 2023, to address Iran's supply of UAVs to Russia for use against Ukraine. The rule adds twelve HTS-6 codes covering UAV-relevant components — aircraft engines, processors, capacitors, memories, and radio navigation equipment — many of which are EAR99 items outside existing ECCNs, requiring a new licence for exports and reexports to Iran. Simultaneously, the rule expands the existing Russia/Belarus FDP rule to cover these same items, closing a gap where foreign-produced items derived from US technology could transit to Russia via Iran without triggering EAR licence requirements.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding seven Iranian entities to the Entity List effective 31 January 2023, for contributing to Russia's military and defense industrial base through the production and transfer of Iranian unmanned aerial vehicles (UAVs) used by Russia in Ukraine. The entities — including Shahed Aviation Industries, Qods Aviation Industry, and arms of the Islamic Revolutionary Guard Corps — are subject to a license requirement with a presumption of denial for all EAR-jurisdiction items. The rule applies the Russia/Belarus Military End User Foreign Direct Product (FDP) rule to all seven entities, extending its reach to foreign-produced items destined for or routed through these Iranian UAV producers.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) on 8 February 2022 to add 33 persons — all based in China — to the Unverified List (UVL) under EAR §744.15(c), on the basis that BIS could not satisfactorily complete end-use checks for these entities for reasons outside US Government control. Placement on the UVL bars exporters from using any EAR license exception when shipping controlled items to listed parties and requires exporters to obtain a certified UVL Statement from the entity or secure a BIS export licence. Sectors represented include semiconductor manufacturing equipment, optoelectronics, UAVs, specialty chemicals, and biotechnology.

The Bureau of Industry and Security (BIS) issued an interim final rule on January 15, 2021 substantially expanding the Export Administration Regulations (EAR) Part 744 end-use and end-user control framework to cover military-intelligence entities in China, Cuba, Iran, North Korea, Russia, Syria, and Venezuela. The rule created a new license requirement for exports of ANY EAR-subject item to named military-intelligence end-users — including EAR99-classified items — and separately imposed restrictions on U.S. persons worldwide providing "support" to military-intelligence end-uses or end-users without a BIS licence. It also broadened chemical and biological weapons controls from "will directly assist" to "will support," expanding the reach of §744.4 and §744.3 on WMD-delivery systems. A technical correction published March 17, 2021 (FR Doc 2021-05623) fixed a drafting error in Instruction 9 that would have inadvertently deleted §744.3(a)(3)(i)-(ii), the rocket systems and UAV provisions.