Industrial Policy & Trade Monitor· 2666 actions· ✨ 90 recent

The Bureau of Industry and Security added 36 entities — 35 in China, 1 in Japan — to the Entity List under a presumption of denial for all EAR-controlled items, effective December 16, 2022. The most consequential additions are Yangtze Memory Technologies (YMTC, simultaneously removed from the Unverified List), eight Cambricon AI-chip subsidiaries, and Shanghai Micro Electronics Equipment (SMEE), China's sole domestic lithography producer. Three existing entries were revised: CETC 13 and two affiliates gained a Footnote 3 Russian-military-end-user designation, bringing them under the Russia/Belarus Foreign Direct Product rule with a blanket denial policy.

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 Bureau of Industry and Security added 24 entities across 26 entries to the Entity List, effective December 8, 2022, covering Latvia, Pakistan, Russia, Singapore, Switzerland, and the United Arab Emirates. Three distinct enforcement clusters are addressed: Russian defense-electronics firms and their foreign affiliates supporting Russia's military-industrial base post-Ukraine invasion; Singapore-based front companies that supplied controlled items to PASNA, an Iran-based Specially Designated National; and Pakistani and Emirati entities engaged in unsafeguarded nuclear activities and ballistic-missile proliferation. One entity (Safe Technical Supply Co., LLC) was simultaneously removed from three entries covering Oman, Saudi Arabia, and the UAE.

Switzerland's Federal Council amended the Ordinance on measures in connection with the situation in Ukraine (SR 946.231.176.72) to align with the EU's eighth sanctions package, effective 6pm on 23 November 2022. The amendment creates the Swiss legal basis for an oil price-cap mechanism — banning maritime transport to third countries of Russian-origin crude oil and petroleum products unless purchased at or below a price cap to be set later (the G7/EU $60/bbl cap followed on 3 December 2022; see the companion US OFAC determination of 2022-12-05). It also extends import/export restrictions to additional iron and steel products and aerospace goods, bans the provision of IT, engineering, architecture and legal services to the Russian government and Russian companies, bans Swiss nationals from holding board seats at certain Russian state-owned companies, fully bans crypto-asset wallet/account/custody services to Russian persons regardless of value, and adopts an arms embargo against Russia (extended in part to Ukraine for reasons of Swiss neutrality).

On 18 October 2022, Crown Prince Mohammed bin Salman launched Saudi Arabia's National Industrial Strategy (NIS) under the Vision 2030 umbrella, with delivery led by the Ministry of Industry and Mineral Resources (MIM). The strategy prioritises 118 segments within 12 industrial sub-sectors (including downstream chemicals, automotive, aerospace, machinery, and metals), identifies more than 800 investment opportunities estimated at ~USD 266bn, and sets binding 2030/2035 targets: triple manufacturing GDP by 2030, raise industrial exports to SAR 557bn (~USD 148bn), bring cumulative additional investment to SAR 1.3 trillion, and grow factories from ~10,000 to ~36,000 by 2035. NIS sits alongside the National Industrial Development and Logistics Program (NIDLP, 2019) and the Public Investment Fund's strategic-sector mandates as the third leg of the Kingdom's non-oil-economy build-out.

On 6 October 2022 the Council of the European Union adopted Council Regulation (EU) 2022/1904, amending Regulation (EU) No 833/2014, as the EU's eighth package of restrictive measures against Russia. It entered into force 7 October 2022. The regulation's headline measure creates the legal basis for an oil price-cap mechanism: a ban on maritime transport to third countries of Russian-origin crude oil and petroleum products, becoming operational once the Council sets an actual cap level by a separate decision (the G7/EU $60/bbl cap followed on 3 December 2022). The package also expands import bans on steel products (phased through 2024), firearms and ammunition, wood pulp and paper, and certain chemicals, cosmetics and jewellery materials; extends export bans on aviation-sector goods; bans the provision of architectural, engineering, IT-consultancy and legal advisory services to the Russian government and Russian companies; and imposes restrictions on Russian-flagged vessels at the Russian Maritime Register.

The Bureau of Industry and Security added 57 entities under 57 entries to the Entity List, effective September 30, 2022, in direct response to Russia's ongoing invasion of Ukraine and its illegal annexation of Ukrainian regions. Of the 57 entities, 56 are listed under Russia and one (Subsidiary Sevastopol Naval Plant of Zvezdochka Shipyard) under the Crimea Region of Ukraine. The additions span aviation repair and overhaul facilities, aerospace R&D institutes, naval propulsion, ballistic-missile producers, advanced-materials and quantum science institutes, and the federal metrology agency; 50 of the 57 receive footnote 3 designations as Russian military end users, subjecting them to the Russia/Belarus-Military End User Foreign Direct Product Rule. All are added with a license review policy of denial for all EAR-subject items except food and medicine designated EAR99.

The U.S. Bureau of Industry and Security (BIS) added seven Chinese entities — under seven entries — to the Entity List, effective August 24, 2022, for acquiring or attempting to acquire U.S.-origin items in support of China's military modernization efforts. The entities span China's state-owned aerospace, space-technology, electronics, and control-systems research institutes. All seven entries carry a license requirement covering all items subject to the EAR, with a presumption-of-denial review policy.

The Bureau of Industry and Security (BIS) amended the Commerce Control List (CCL) under the Export Administration Regulations (EAR) to implement four emerging and foundational technology decisions agreed at the December 2021 Wassenaar Arrangement Plenary meeting, pursuant to ECRA Section 1758. The rule adds new export controls on ultra-wide bandgap semiconductor substrates (gallium oxide Ga₂O₃ and diamond), ECAD software for Gate-All- Around Field-Effect Transistor (GAAFET) integrated circuit development, and Pressure Gain Combustion (PGC) technology for advanced gas turbine engines. Controls require a licence for items destined to countries listed in the NS:1 and AT:1 columns of the Commerce Country Chart; ECAD software controls (ECCN 3D006) have a delayed compliance date of October 14, 2022.

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 US Department of Commerce Bureau of Industry and Security (BIS) added 71 entities — 70 Russian and 1 Belarusian — to the Entity List, effective June 2, 2022, in direct response to Russia's further invasion of Ukraine on February 24, 2022. The entities were designated as military end users acquiring or attempting to acquire US-origin items in support of Russia's military, and are subject to a policy of denial for all items subject to the Export Administration Regulations (EAR). Sixty-six entities receive a "footnote 3" military end-user designation, while five face outright denial with no license exceptions available beyond humanitarian food and medicine.

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.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 120 entities under 120 entries to the Entity List, effective 1 April 2022 and published in the Federal Register on 7 April 2022. All 120 entities — located in Russia and Belarus — were determined to be acting contrary to US national security or foreign policy interests in the context of Russia's further invasion of Ukraine beginning 24 February 2022. The rule imposes a presumption-of-denial policy for all EAR-subject items and prohibits all license exceptions for exports, reexports, or in-country transfers to the listed parties. Ninety-five of the 120 entities are additionally designated under Footnote 3 of the Entity List as military end users, triggering the Russian/Belarusian Military End User foreign-produced direct product rule (MEU FDP Rule), extending US extraterritorial reach to non-US items made with US-origin technology.

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.

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.

The Department of Commerce Bureau of Industry and Security (BIS) added 91 entities (across 96 entries) to the Entity List under 15 CFR Part 744, in direct response to Russia's further invasion of Ukraine on 24 February 2022. The listed entities span ten destinations — Belize, Estonia, Kazakhstan, Latvia, Malta, Russia, Singapore, Slovakia, Spain, and the United Kingdom — and include Russian military research institutes, shipbuilding facilities, aerospace and electronics manufacturers, and suspected front companies in third countries used to circumvent EAR controls. A license is required for all items subject to the EAR; the review policy is denial for 86 entities and case-by-case (for US Government-supported space programs) for five.

On 6 March 2022, the South Korean government determined that Belarus had materially supported Russia's invasion of Ukraine and announced it would extend the export-control measures already applied to Russia to Belarus as well. Effective 7 March 2022, Korea designated two Belarusian entities (Belarus's Ministry of Defence and a second entity) to its "parties of concern" list, triggering a case-by-case licensing requirement for strategic items under Korea's multilateral export-control regime, and tightened review of non-strategic dual-use items destined for Belarus.

On 4 March 2022 Switzerland's Federal Council adopted a total revision of the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), taking effect the same day at 18:00, to fully implement the EU's sanctions packages of 23 and 25 February 2022. The revision bans export of all dual-use goods to Russia regardless of end use or end user, bans export of goods that could contribute to Russia's military or technological strengthening or its defence and security sector, and prohibits export of specified goods and services to the oil sector, as well as goods for aviation, space and oil-refining/gas-liquefaction use.

Effective 2 March 2022, the US Bureau of Industry and Security (BIS) extended to Belarus the same sweeping EAR sanctions imposed on Russia following Russia's full-scale invasion of Ukraine on 24 February 2022. The rule adds Commerce Control List (CCL)-based license requirements for Belarus with a policy of denial across virtually all categories, extends both the Russia Foreign Direct Product (FDP) rule and the Russia Military End User (MEU) FDP rule to cover Belarus and Belarusian military end users, and aligns Belarus with Russia's license review policy. The action was triggered by Belarus's active enablement of the Russian military operation from its territory.

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.

Effective 24 February 2022 — the date of Russia's full-scale invasion of Ukraine — the US Bureau of Industry and Security (BIS) published an interim final rule (87 FR 12226, FR Doc 2022-04300) adding sweeping new export license requirements under a new § 746.8 of the Export Administration Regulations (EAR). The rule requires a licence for any item in CCL Categories 3–9 (electronics, computers, telecommunications, sensors, lasers, navigation/avionics, marine, aerospace, propulsion) exported, reexported, or transferred to Russia, with a review policy of denial. Two new Russia-specific Foreign Direct Product (FDP) rules extend US jurisdiction to foreign-manufactured goods: the Russia FDP Rule (§ 734.9(f)) covers all foreign-made items using US technology/equipment destined for Russia, and the Russia-MEU FDP Rule (§ 734.9(g)) covers items destined to 47 designated military-end-user (MEU) entities with no licence exceptions available. All three restrictions carry a presumption of denial, making this the most sweeping peacetime expansion of the EAR since its modern codification.

OFAC codified the Chinese Military-Industrial Complex Sanctions Regulations at 31 CFR Part 586, implementing Executive Order 13959 (November 12, 2020) as amended by Executive Order 14032 (June 3, 2021). The regulations prohibit US persons from purchasing or selling publicly traded securities of entities designated on OFAC's Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List, which identifies firms determined to support the People's Liberation Army or Chinese surveillance-technology programs. A divestment deadline of June 3, 2022 applied to entities named in the original EO 13959 annexes; future additions carry a one-year divestment window from the date of designation.

Effective 3 February 2022, the Bureau of Industry and Security published a final rule (87 FR 6231, FR Doc 2022-02302) consolidating all existing Foreign Direct Product (FDP) rules from scattered locations in EAR Parts 736 and 744 into a single new section, 15 CFR §734.9, under Part 734 (Scope of the EAR). The rule made no substantive changes to existing controls — it reorganised four pre-existing FDP rules (National Security, 9x515, 600 Series, and Entity List) into a clean §734.9(b)–(e) architecture, clarified the definition of "major component" at §734.9(a), and corrected a drafting ambiguity that had obscured the U.S.-origin technology trigger for three of the four rules. The newly created §734.9 structure became the vehicle used by BIS to add the Russia/Belarus FDP rule (§734.9(f)) just 21 days later, on 24 February 2022.