Industrial Policy & Trade Monitor· 2666 actions· ✨ 89 recent

On May 1, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated China-based independent ("teapot") refinery Hengli Petrochemical (Dalian) Refinery Co., Ltd. — described as China's second-largest teapot — together with approximately 40 shipping firms and vessels operating as part of Iran's shadow fleet. OFAC sanctioned 19 shadow-fleet vessels (crude, LPG, and petrochemical tankers) as blocked property of designated owners or managers. The action was taken under Executive Order 13902 (Iran petroleum and petrochemical sectors) in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. Treasury press release SB0472. Concurrent with the designations, OFAC issued Iran-related General License W authorising the wind-down of transactions involving the persons newly blocked on May 1, 2026, and published a structurally novel Iran-related Alert, "Sanctions Risks of Iranian Demands for Strait of Hormuz Passage." The Alert states that payments to the Government of Iran or the IRGC — directly or indirectly — for safe passage through the Strait of Hormuz are not authorised for US persons (including US financial institutions) or US-owned/-controlled foreign entities. OFAC also issued new FAQ 1250 to accompany the Alert and GL W. The wave is one of the largest single-day Iran enforcement actions of the Trump 2.0 administration. Treasury characterises it as part of a campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The Strait of Hormuz Alert is the operational US response to Iranian regulatory threats against the ~20% of global oil and ~25% of global LNG transiting Hormuz, putting tanker owners, P&I clubs, flag states, and oil-buyer compliance teams on direct notice.

On April 24, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) added 19 entities and 19 vessels to the Specially Designated Nationals (SDN) List under Executive Order 13902 (Iran petroleum and petrochemical sectors), in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. The action is the first OFAC designation of a Chinese independent ("teapot") refinery — Hengli Petrochemical (Dalian) Refinery Co., Ltd., described as one of Iran's largest single customers for crude oil and petroleum products, having purchased billions of US dollars' worth since at least 2023 from cargoes brokered by Sepehr Energy Jahan Nama Pars Company (the oil sales arm of Iran's Armed Forces General Staff, controlled by the Ministry of Defense / MODAFL). Co-designations span shipping firms and vessels registered in China, Hong Kong, Panama, Marshall Islands, Liberia, and Vietnam. Concurrent with the designations, OFAC issued Iran-related General License V authorising a 30-day wind-down (through May 24, 2026) of transactions involving Hengli Petrochemical (Dalian) Refinery Co., Ltd. and certain majority-owned entities. Treasury press release SB0472 ("Economic Fury Targets Global Network Fueling Iran's Oil Trade and Shadow Fleet") frames the action as part of the maximum-pressure campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The April 24 designations directly triggered the first-ever operational use of China's Blocking Rules (MOFCOM Announcement No. 21 of May 2, 2026) and preceded a second OFAC Iran wave on May 1, 2026 (General License W + Strait of Hormuz Sanctions Risk Alert).

The US Treasury's Office of Foreign Assets Control designated 18 individuals and entities that make up the "rahbar" shadow-banking networks of sanctioned Iranian banks Bank Melli and Shahr Bank, including Singapore-based Golden Mist PTE Ltd, UAE-based Empire International Trading FZE and HMS Trading FZE, Iran-based Nikan Pezhvak Aria Kish Company and Tejarat Hermes Energy Qeshm, and UK-based Nanshan Ltd. Separately, OFAC designated senior Iranian security officials, including SCNS Secretary Ali Larijani, for their role in the regime's violent crackdown on peaceful protesters that began in December 2025. The financial designations were made under E.O. 13902 (Iran's financial/petroleum/petrochemical sectors) and the human-rights designations under E.O. 13553 and E.O. 13876, in furtherance of NSPM-2; Treasury noted it sanctioned more than 875 persons, vessels, and aircraft under the same maximum-pressure campaign in 2025.

On 8 September 2025, Spanish Prime Minister Pedro Sánchez announced a nine-measure package against Israel over the Gaza war, the centrepiece being urgent approval of a Royal Decree-Law to permanently codify in law the arms embargo Spain had applied de facto since October 2023 — a total ban on buying and selling arms, ammunition, military equipment and dual-use goods with Israel, plus a ban on port transit of fuel for the Israeli military and a ban on Israeli state aircraft carrying defence material transiting Spanish airspace. The package also bans importing, advertising and marketing products originating from Israeli settlements in the occupied West Bank and Gaza. The Council of Ministers formally approved the measure as Real Decreto-ley 10/2025 on 23 September 2025; it was published in the BOE on 24 September 2025 (BOE-A-2025-18831) and validated by Congress on 8 October 2025 (178–169). Spain's Ministry of Economy, Trade and Business separately disclosed that 219 defence-material export/import licences to Israel had been denied since October 2023, against a bilateral trade backdrop of roughly €50M in Spanish arms exports to Israel (Jan 2023–Jun 2024) and at least €54.4M in Spanish imports of Israeli arms/munitions (Oct 2023–May 2025, DataComex code 93).

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 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.

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

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

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 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.

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.

The Sanctions and Anti-Money Laundering Act 2018 (SAMLA, Chapter 13) received Royal Assent on 23 May 2018 and established the UK's autonomous post-Brexit sanctions legal framework. Part 1 empowers Ministers (FCDO, HM Treasury) to impose financial, trade, immigration, aircraft, and shipping sanctions by statutory instrument for purposes including UN compliance, national security, foreign-policy objectives, and promotion of human rights and democracy. Part 2 grants Ministers authority to make AML and counter-terrorist-financing regulations aligned with FATF standards, previously derived from EU Anti-Money-Laundering Directives. SAMLA is the parent enabling statute for every UK sanctions regime in force post-Brexit, including 30+ thematic and geographic regulations covering Russia (SI 2019/855), Iran, DPRK, Belarus, Myanmar, Syria, Venezuela, cyber, chemical weapons, global anti-corruption, and global human rights; under SAMLA, OFSI (HM Treasury) holds civil monetary-penalty and criminal-referral enforcement powers. Structurally peer to US IEEPA, EU Council Regulation framework, CN AFSL 2021, and JP FEFTA as the G7+CN foundational sanctions-statute cluster.