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

On 2 May 2026, MOFCOM issued Announcement No. 21 of 2026 — the first concrete prohibition order ever issued under China's 2021 "Rules on Counteracting Unjustified Extra-territorial Application of Foreign Legislation and Other Measures" (Blocking Rules) and the Anti-Foreign Sanctions Law (AFSL). The order prohibits any Chinese organisation, individual, or foreign party operating in China from recognising, enforcing, or complying with US sanctions imposed under Executive Orders 13902 and 13846 against five Chinese independent ("teapot") refineries — Hengli Petrochemical (Dalian) Refining Co., Ltd., Shandong Shouguang Luqing Petrochemical Co., Ltd., Shandong Jincheng Petrochemical Group Co., Ltd., Hebei Xinhai Chemical Group Co., Ltd., and Shandong Shengxing Chemical Co., Ltd. — all designated by OFAC for purchasing Iranian crude. The announcement is the first operational test of the framework built up across the AFSL (2021), the AFSL Implementation Regulations (Order 803, March 2025), and State Council Order 835 on Countering Foreign Unlawful Extraterritorial Jurisdiction (April 2026), and creates a direct compliance conflict for banks, insurers, traders, and shipping companies operating in or with China that had been winding down their exposure to the listed refineries.

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 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.

HM Treasury's Office of Financial Sanctions Implementation (OFSI) published a Russia-regime notice on 18 December 2025 designating five individuals and 19 entities under the Russia (Sanctions) (EU Exit) Regulations 2019. Of the 19 entities, six are based in Russia, eight in the United Arab Emirates, four in Uzbekistan and one in Kyrgyzstan — reflecting OFSI's continued focus on third-country intermediaries used to route sanctioned Russian trade and finance. Designated persons are subject to a full asset freeze and are barred from commercial transactions and investment instruments with UK persons.

On 23 October 2025, the Council of the European Union adopted the 19th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/2033 amending Regulation 833/2014 (sectoral sanctions), Council Implementing Regulation (EU) 2025/2035 amending Regulation 269/2014 (asset-freeze listings — 22 individuals + 42 entities, total 69 listings), and Council Regulation (EU) 2025/2041 (parallel Belarus measures). The package closes the Russian-LNG import loophole left open by the 18th package and establishes the architectural template for crypto-asset sanctions. Headline measures: (i) full prohibition on imports of Russian-origin LNG into the EU — short-term contracts banned six months from entry into force (effective 25 April 2026), long-term contracts (> 1 year, executed before 17 June 2025) phased out by 1 January 2027; (ii) full transaction ban on Rosneft and Gazprom Neft (tightening prior partial measures); (iii) five additional Russian banks added to Annex XIV transaction ban (Alfa-Bank, MTS Bank among them; effective 12 November 2025); (iv) full transaction bans on the Mir card payment system and the Faster Payments System (SBP), effective 25 January 2026; (v) first-ever EU sanctions on a stablecoin — the rouble-backed A7A5 (issuer + developer designated) — and a Paraguay-based cryptocurrency exchange used as a circumvention rail; (vi) prohibition on EU operators contracting with 11 listed Russian Special Economic Zones (Annex LII), with mandatory divestment from Alabuga (Tatarstan) and Technopolis Moscow effective 25 January 2026 — no five-year wind-down available; (vii) 45 entities added to Annex IV military end-user list (28 Russian + 17 third-country: 12 Chinese/Hong Kong, 3 Indian, 2 Thai); (viii) new export restrictions on electronic components, microelectronics, acyclic hydrocarbons, pneumatic rubber tires and propellant chemicals (~EUR 155 m of EU 2024 exports); (ix) prohibition on supply of AI, HPC, and quantum-computing services to Russian persons (effective 25 November 2025); (x) tourism-services ban (1 January 2026 wind-down); (xi) 117 additional shadow-fleet vessels listed (cumulative 557, exceeding the 18th package's 444); (xii) four Belarus + Kazakhstan banks listed for SPFS use (effective 2 December 2025); (xiii) binding ownership/control definitions added to Reg. 269/2014 (50 % proprietary-rights threshold + eight-criterion control test). Entry into force on 24 October 2025 (day following publication in OJ L_202502033), except for measures with explicit deferred application dates.

On 23 October 2025, the Council of the European Union adopted Council Regulation (EU) 2025/2041 (amending Regulation (EC) No 765/2006) and Council Decision (CFSP) 2025/2040 (amending Decision 2012/642/CFSP), widening the EU's Belarus restrictive-measures regime in lockstep with the 19th Russia sanctions package adopted the same day. The package widens the export ban to industrial goods (salts, ores, rubber articles, tyres, millstones, construction materials, electronic components, rangefinders, propellant chemicals, metals/oxides/alloys), extends the import ban to all acyclic hydrocarbons, introduces a new prior-licensing requirement for services supplied to Belarus, its government, or public bodies, and mirrors the Russia regime's space, AI, and high-performance/ quantum-computing service restrictions. A companion instrument, Council Implementing Regulation (EU) 2025/2039, adds 5 new asset-freeze listings (2 individuals + 3 entities, including JSC Holography Industry, Horizont Holding, and ICT Horizont). Entered into force 24 October 2025.

On 9 October 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated more than 50 individuals, entities and vessels for facilitating Iranian crude oil, petroleum-product and liquefied petroleum gas (LPG) exports, in a coordinated action with the State Department. The network included 33 vessels transporting Iranian crude and LPG, shipping entities registered in Panama, the Marshall Islands, Ukraine and Liberia, an Iranian petrochemical producer, four Turkish petrochemical trading entities, five Chinese entities importing/refining/storing Iranian petroleum (including a China-based petrochemical-terminal operator, Jiangyin Foreversun Chemical Logistics Co., Ltd.), three Singapore-based logistics entities, and 27 entities based in Hong Kong, the UAE and India engaged in trading and shipping. The action was taken pursuant to the National Security Presidential Memorandum 2 (NSPM-2) maximum-pressure campaign against Iran and blocks all US property/interests of the designated parties, exposing non-US counterparties to secondary-sanctions risk.

On 6 October 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated 8 Mexican individuals and 12 Mexico-based companies under Executive Order 14059 for supplying fentanyl precursor chemicals and laboratory equipment to the Sinaloa Cartel's "Los Chapitos" faction, led by fugitive brothers Archivaldo Ivan and Jesus Alfredo Guzman Salazar (sons of Joaquin "El Chapo" Guzman Loera). The network is centred on Sumilab, a chemical and lab-equipment supplier previously sanctioned by OFAC in May 2023, which restructured through affiliated pharmaceutical, laboratory, chemical, cleaning-supply and real-estate front companies to continue operating after the earlier designation. All property and interests in property of the designated persons within US jurisdiction or held by US persons are blocked, and US persons are generally prohibited from transacting with them.

On 12 September 2025 the UK government, acting under the Russia (Sanctions) (EU Exit) Regulations 2019, designated 3 individuals and 27 entities — 19 Russian, plus third-country intermediaries in Thailand (3), Hong Kong (3), India (1) and Türkiye (1) accused of supplying electronics, chemicals and explosives used in Russian missile and weapons production — and proscribed 70 vessels (oil tankers and cargo ships, identified by IMO number) linked to Russia's shadow fleet evading the G7 crude price cap. The package brings the UK's cumulative tanker designations to nearly 500, more than any other single jurisdiction.

On 3 September 2025, the U.S. Treasury's Office of Foreign Assets Control (OFAC) designated Guangzhou Tengyue Chemical Co., Ltd., a China-based chemical manufacturer, along with two of its representatives, Huang Xiaojun and Huang Zhanpeng, pursuant to Executive Order 14059 for materially contributing to the international proliferation of illicit drugs. The company was found to have manufactured and sold synthetic opioids — including nitazenes — and analgesic cutting agents such as xylazine and medetomidine to U.S. buyers. The designation blocks all U.S.-person property and transactions involving the three designated persons and any entity 50%-or-more owned by them; the FBI simultaneously announced a related federal indictment against Guangzhou Tengyue, the two individuals, and roughly 22 other China-based individuals and businesses for conspiracy to commit drug trafficking.

Presidential Decree No. 606 of 29 August 2025 amends the standing list of foreign-owned Russian assets under "temporary management" (established by Decree No. 302 of 25 April 2023) to add the shares of Air Liquide's Russian subsidiaries, transferring control to M-Logistika LLC, a Russian company. Reported affected entities include Air Liquide's joint venture with steelmaker Severstal and regional operating units (Alabuga, Balakovo, Lipetsk, Ryazan, Kstovo, Kuzbass, Sever Liquid Gas), covering the bulk of the French industrial-gas group's Russian footprint. The decree entered into force on its date of official publication and is one of a running series of company-specific amendments to Decree 302, Russia's reciprocal-response mechanism for placing "unfriendly state" companies' Russian assets under state administration.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) announced a $3,882,797 civil settlement with Unicat Catalyst Technologies LLC, an Alvin, Texas-based specialty catalyst supplier, resolving 13 apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 CFR Part 560) and one apparent violation of the Venezuela Sanctions Regulations (VSR, 31 CFR Part 591). OFAC determined the conduct egregious; Unicat had voluntarily self-disclosed. The settlement was concurrent with separate actions by the U.S. Department of Justice and the Department of Commerce Bureau of Industry and Security (BIS). The violations, spanning 2016–2021, involved the supply of catalyst products and consulting services to Iranian customers via a Dutch affiliate and Chinese supplier, and the sale of catalysts to Orinoco Iron S.C.S., a blocked Venezuelan government-owned entity, routed through a Chinese intermediary.

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

On 11 October 2024, the Secretary of the Treasury — acting in consultation with the Secretary of State and pursuant to section 1(a)(i) of Executive Order 13902 — determined that the petroleum and petrochemical sectors of the Iranian economy are sectors of strategic concern, exposing non-US persons that operate in or knowingly facilitate significant transactions with those sectors to secondary sanctions and SDN-listing risk. The determination was issued in response to Iran's 1 October 2024 ballistic- missile attack on Israeli targets and was formally published in the Federal Register on 19 November 2024 (FR Doc 2024-26800). Concurrent with the determination, OFAC designated an international network — including Sepehr Energy Jahan Nama Pars — that had shipped millions of barrels of Iranian crude on behalf of Iran's Armed Forces General Staff to the People's Republic of China.

Poland's Minister of Development and Technology, Waldemar Buda, established a temporary compulsory administrator (tymczasowy zarządca przymusowy) over the Grupa Azoty S.A. shares held by sanctioned Russian oligarch Vyacheslav Kantor through three holding vehicles — Norica Holding S.à r.l. (Luxembourg), Opansa Enterprises Limited and Rainbee Holdings Limited (both Cyprus) — which together controlled 19.82% of the state-linked fertiliser and chemicals group, worth over PLN 0.5bn. The ministry cited Kantor's inclusion on Poland's sanctions list and the protection of the country's economic and energy security, and stated its intent to find a buyer for the stake and compensate Kantor. The Provincial Administrative Court in Warsaw (WSA) later overturned the decision establishing the administration; the ministry did not appeal, and the ruling became final around 30 July 2024, ending the administrator's mandate — though the underlying EU/Polish sanctions on Kantor continue to freeze his ability to exercise any rights attached to the shares.

Switzerland's Federal Council amended the Ordinance on measures related to the situation in Ukraine (SR 946.231.176.72) to align with the remainder of the EU's tenth sanctions package, effective 8pm on 29 March 2023. The amendment extends the existing Russia import ban to additional petroleum products (including petroleum jelly and petroleum coke), bitumen/asphalt, bituminous mastics, carbon and synthetic rubber, adds further export controls and designations linked to drone transfers to Russia, and tightens reporting obligations in the financial sector.

On 25 February 2023, one year into Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Council Regulation (EU) 2023/427, the 10th package of sanctions, amending Regulation (EU) 833/2014. It entered into force on publication the following day (26 February 2023). The package bans imports of asphalt and synthetic rubber from Russia (with a temporary transitional import quota for rubber products running to 30 June 2024), expands the export ban on dual-use and advanced-technology goods, suspends further Russian media broadcasting licences in the EU, and designates 87 individuals and 34 entities — including Iranian persons and entities involved in drone manufacture and supply, and 96 entities tied to Russia's defence-industrial base — to the EU asset-freeze/travel-ban list.

On 24 February 2023, to mark the one-year anniversary of Russia's full-scale invasion of Ukraine, the UK government announced a new sanctions package including an import ban on over 140 goods (including iron and steel products processed in third countries), an export ban on battlefield-relevant goods, and 92 new asset-freeze designations. The measures were legislated by the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023 (SI 2023/440), which came into force on 21 April 2023, except the third-country-processed iron and steel import provision (Regulation 3), which came into force on 30 September 2023.

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.

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.

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.

On 8 April 2022 the Council of the European Union adopted Regulation (EU) 2022/576, further amending Regulation (EU) No 833/2014 (the fifth package of measures against Russia). It bans imports of Russian coal and other solid fossil fuels, wood, cement, rubber, fertilisers, high-end seafood and spirits; bans exports to Russia of jet fuel, quantum computers, advanced semiconductors, high-end electronics and sensitive machinery; bars Russian and Belarusian road-freight operators from EU territory; and closes EU ports to Russian-flagged vessels. It entered into force on 9 April 2022, the day after publication in the Official Journal (OJ L 111).

The Biden administration on 2 March 2021 determined, pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act), that Russia used a Novichok-class nerve agent against opposition figure Alexei Navalny in August 2020 — the third CBW Act invocation against Russia (after Salisbury 2018 and its follow-on 2019 round). The determination triggered mandatory statutory sanctions including termination of US foreign assistance to Russia (except humanitarian aid and food/agricultural commodities), suspension of US arms and defense-article sales and export authorisations to Russia, and denial of US government credit and financial assistance. Seven Russian government officials linked to the poisoning were concurrently designated by Treasury/OFAC. The measures take effect after a mandatory 15-day congressional notification period and remain in force for at least 12 months unless Russia certifies Chemical Weapons Convention compliance and takes other required steps.