Industrial Policy & Trade Monitor· 2665 actions· ✨ 90 recent

On June 21, 2026, OFAC issued Iran-related General License X (GL X), authorizing transactions otherwise prohibited under the Iranian Transactions and Sanctions Regulations (31 CFR part 560), the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587), the Ukraine-/Russia-Related Sanctions Regulations (31 CFR part 589), and WMD-proliferation sanctions authorities — including new purchases and loadings of Iranian-origin crude oil, petrochemical, and petroleum products, a materially broader carve-out than the cargo-already-loaded window granted by the preceding General License U. Just 16 days later, on July 7, 2026, OFAC issued General License X1, revoking and superseding GL X: as of that date new purchases or loadings of Iranian-origin crude oil, petrochemical, or petroleum products were no longer authorized. GL X1 itself subsequently expired. OFAC formally published both web licenses in the Federal Register on September 30, 2026 — a retrospective publication of licenses already issued and, by then, already revoked and expired.

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).

On 23 April 2026, the Council of the European Union adopted the 20th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2026/506 amending Regulation 833/2014 (sectoral sanctions) and Council Regulation (EU) 2026/511 amending Regulation 269/2014 (asset-freeze listings — 120 additional individuals and entities, the largest single tranche in two years). The package operationalises and extends the crypto-sanctions architecture introduced in the 19th package and constructs the legal scaffolding for a future full prohibition on maritime services to vessels carrying Russian crude/petroleum products. Headline measures: (i) full sectoral prohibition on transactions with crypto-asset service providers and exchange platforms established in Russia or Belarus, plus designation of the rouble-backed stablecoin RUBx and the digital rouble (CBDC) on Annex LIII — effective 24 May 2026, with EU support for the digital rouble's development banned outright; (ii) 36 new energy-sector listings spanning upstream extraction, refining and transportation; (iii) prohibition on providing technical, financial, brokering and insurance services to Russia-flagged, Russian-certified or Russian-managed LNG tankers and icebreakers effective 25 April 2026, extending to foreign-flagged vessels operating in Russian interests by January 2027 and culminating in a categorical ban on LNG terminal services to Russian-controlled entities on 1 January 2027; (iv) full transaction ban on 20 Russian banks plus four third-country banks listed for SPFS connectivity / sanctions circumvention; (v) 46 newly listed shadow-fleet vessels and new tanker sale-due-diligence obligations on EU shipping operators; (vi) 58 designations of companies and associated individuals in the Russian military-industrial complex including drone developers/manufacturers; (vii) further Annex IV third-country circumvention enabler listings (China, Hong Kong, Turkey, UAE); (viii) parallel measures against Belarus. Entry into force on 24 April 2026 (day following publication in OJ L_202600506), except for measures with explicit deferred application dates.

ALNAFT officially launched the Algeria Bid Round 2026 on 19 April 2026 in Algiers, offering seven onshore exploration/development perimeters (Est Bordj Omar Driss I, Illizi Centre I, El M'Zaid Nord, El Borma II, El Hadjira III, El Benoud Est, Touggourt Sud) located in the Ouargla, Illizi, Touggourt, and El Bayadh hydrocarbon provinces. The round operates under the Loi n° 19-13 hydrocarbons framework, with the virtual data room (VDR) opening 1 June 2026, bids due 26 November 2026, and contracts to be signed no later than 31 January 2027. The initiative is Algeria's first structured multi-block bid round since the 2019 framework law restructured the upstream contractual and institutional architecture, and is materially significant to EU gas-import diversification given Algeria's approximately 12% share of EU gas supply via the Medgaz and Transmed pipelines plus LNG.

President Ferdinand R. Marcos Jr. signed Executive Order No. 110 on March 24, 2026, declaring a one-year State of National Energy Emergency in response to Middle East supply disruptions, including potential closure of the Strait of Hormuz, that threaten petroleum import flows to the Philippines. The order activates the Unified Package for Livelihoods, Industry, Food, and Transport (UPLIFT), suspends normal procurement requirements for emergency energy acquisition, grants the Department of Energy (DOE) emergency fuel-import authority, and releases a ₱20 billion emergency fund to secure fuel supply. The emergency regime also mandates accelerated renewable-energy transition and promotion of EVs in public transport to reduce long-run import dependency.

On March 20, 2026, OFAC issued Iran-related General License U (GL U), temporarily authorizing the sale, delivery, offloading and — notably, for the first time in decades — importation into the United States of Iranian-origin crude oil and petroleum products, but only for cargo already loaded onto vessels as of 12:01 a.m. EDT that day. The window ran through April 19, 2026, after which the authorization lapsed. The license excluded any transaction touching Cuba, North Korea, or Russian-government-controlled areas of Ukraine, and did not waive any other, non-Iran sanctions program. OFAC formally published GL U (and the separate, entity-specific GL V wind-down license for Hengli Petrochemical) in the Federal Register on June 10, 2026 — a retrospective publication of licenses already issued and, by then, already expired.

On 12 March 2026 Senegal's Primature held a press conference releasing mid-term findings of the National Commission for the Re-evaluation and Renegotiation of Petroleum, Gas, and Mining Contracts, created in August 2024 under Prime Minister Ousmane Sonko's reform programme. The Commission identified a 1,075.9 billion FCFA shortfall in the mining sector — concentrated in unpaid taxes/royalties and unauthorised tax exemptions at ICS (Industries Chimiques du Sénégal) — and announced the termination of four offshore oil-exploration blocks (Djifer Offshore, Kayar Offshore, Saint-Louis Offshore, Rufisque Offshore). Renegotiation of the Greater Tortue Ahmeyim (GTA) gas project, operated by BP with Kosmos Energy and Woodside as partners on the Senegal-Mauritania maritime border, is under active examination; the Primature projects 900 bn FCFA in incremental fiscal revenue 2026-2040 from the contract revision programme. This is Senegal's first major instance of retroactive resource-contract review under the Sonko-Faye government and establishes the legal-political baseline for subsequent contract renegotiations across the 27 mining contracts and remaining hydrocarbon licences under Commission review.

On 13 February 2026 President Bola Ahmed Tinubu signed Executive Order No. 9 of 2026 directing all Production Sharing Contract operators and contractors to remit Royalty Oil, Tax Oil, Profit Oil, and Profit Gas directly to the Federation Account, bypassing prior NNPC Limited intermediated collection. The order simultaneously eliminates NNPC Limited's 30% management fee on profit oil/gas, suspends the 30% Frontier Exploration Fund deduction, and redirects Gas Flare Penalty proceeds to the Federation Account — materially walking back the fiscal architecture established under Petroleum Industry Act 2021 §§ 9 and 53. An Implementation Committee chaired by the Minister of Finance was established to operationalise the order and resolve disputes.

President Trump signed Executive Order 14382, "Addressing Threats to the United States by the Government of Iran," on 6 February 2026 (effective 12:01 a.m. EST on 7 February 2026; published in the Federal Register on 11 February 2026 as FR doc 2026-02813, 91 FR 6493-6496). Invoking IEEPA, the National Emergencies Act, section 604 of the Trade Act of 1974 and 3 U.S.C. § 301, the order declared a country-specific national emergency with respect to Iran and established a secondary-tariff-authority framework: an additional ad valorem duty (the EO offers "for example, 25 percent" as illustration but sets no binding rate) is authorised on imports of articles produced by any foreign country determined to directly or indirectly purchase, import, or otherwise acquire any goods or services from Iran. Determinations are made by the Secretary of Commerce, with rate recommendations from the Secretary of State in consultation with Treasury, DHS and USTR; the President retains final authority. EO 14382 was structurally modelled on EO 14245 (Venezuelan oil importing countries, 24 March 2025) and EO 14380 (Cuba, 29 January 2026), and was on the list of nine IEEPA-based tariff EOs whose tariff component was vacated by the SCOTUS 6-3 ruling in *Learning Resources, Inc. v. Trump* (20 February 2026). The companion EO 14389 of 20 February 2026 ("Ending Certain Tariff Actions") extinguished the tariff authority for entries on or after 12:00 a.m. ET on 24 February 2026; the underlying Iran national- emergency declaration was preserved. No third-country determination or specific rate was operationalised under EO 14382 prior to vacatur.

On 6 February 2026 Presidents Trump and Modi announced a framework for an Interim Trade Agreement that resets the bilateral tariff posture installed in 2025. Two operative instruments: (i) an executive order signed 6 February eliminating, effective 7 February 2026, the additional 25% IEEPA "Russian-oil" duty on Indian imports imposed by EO 14329 (27 August 2025), conditional on India's commitment to cease buying Russian crude and to expand defence cooperation; and (ii) reduction of the EO 14257 reciprocal-tariff rate on India from 25% to 18% on listed product categories (textiles and apparel, leather and footwear, plastics and rubber, organic chemicals, home décor, artisanal products, certain machinery), to take effect on finalisation of the Interim Agreement. India commits to eliminate or reduce tariffs on all US industrial goods and a wide range of agricultural products (DDGs, red sorghum, tree nuts, fresh and processed fruit, soybean oil, wine, spirits) and to purchase >USD 500bn of US energy, ICT, coal, aircraft and aircraft parts, and precious-metals products over five years. The framework also commits the parties to negotiating "robust, ambitious, and mutually beneficial digital trade rules" and to addressing non-tariff barriers in medical devices, ICT import licensing, and food/agricultural standards. US tariff reductions on Indian generic pharmaceuticals, gems, diamonds, aircraft parts, and certain automotive components are flagged as contingent on completion of the full Interim Agreement.

On 29 January 2026 Switzerland's Federal Department of Economic Affairs, Education and Research (WBF) amended Annex 28 of the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), lowering the price cap on Russian seaborne crude oil from USD 47.6 to USD 44.1 per barrel, effective 1 February 2026. The amendment prohibits Swiss-domiciled operators from providing financial and transport (maritime, insurance, brokering) services related to Russian crude oil priced above the new cap. Switzerland is not an EU member but autonomously aligns its Ukraine Ordinance with EU sanctions packages; this cut mirrors the EU's Implementing Regulation 2026/124 and the UK OFSI general licence amendment adopted two weeks earlier under the same six-monthly dynamic-adjustment formula.

President Trump signed Executive Order 14380, "Addressing Threats to the United States by the Government of Cuba," on 29 January 2026 (effective 12:01 a.m. EST on 30 January 2026; published in the Federal Register on 3 February 2026 as FR doc 2026-02250, 91 FR 5085-5089). Invoking IEEPA and the National Emergencies Act, the order declared a country-specific national emergency with respect to Cuba, citing Havana's intelligence and defense alignment with Russia, the PRC, Iran, Hamas and Hezbollah — including the Russian signals-intelligence facility hosted on the island. The operative measure was a secondary-tariff-authority framework: the EO authorises additional ad valorem duties on goods imported from any country determined to be selling or otherwise providing oil to the Government of Cuba, whether directly or indirectly. No specific rate was set in the EO itself — rate-setting was delegated to the Secretary of Commerce (in consultation with State, Treasury, DHS and USTR). The EO was structurally analogous to EO 14245 (Venezuelan oil importing countries, 24 March 2025) and was on the list of nine IEEPA-based tariff EOs whose tariff component was vacated by the SCOTUS 6-3 ruling in *Learning Resources, Inc. v. Trump* (20 February 2026); the underlying Cuba national-emergency declaration was preserved by the 20 February 2026 "Ending Certain Tariff Actions" EO, but the tariff authority was extinguished before any third-country determination or rate was operationalised.

On January 23, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated eight vessel-owning/management firms — based in the UAE, India, Oman, the Seychelles, and the Marshall Islands — and identified nine of their tankers as blocked property, for transporting hundreds of millions of dollars' worth of Iranian crude oil, LPG, naphtha and high-sulfur fuel oil to buyers across East Asia, South Asia and East Africa. The action was taken under Executive Order 13902 (Iran petroleum/petrochemical sector) as part of the maximum-pressure campaign under National Security Presidential Memorandum 2, and OFAC concurrently issued General License T authorizing limited safety, environmental and cargo-offloading transactions involving the newly blocked vessels.

On 14 January 2026 the European Commission adopted Implementing Regulation (EU) 2026/124, amending Annex XXVIII to Council Regulation (EU) No 833/2014, lowering the price cap on seaborne Russian crude oil (CN code 2709 00) from USD 47.6 to USD 44.1 per barrel, effective 1 February 2026. This is the first application of the automatic dynamic-adjustment mechanism introduced by the 18th sanctions package (Council Regulation (EU) 2025/1494, July 2025), which re-indexes the cap every six months to 15% below the 22-week trailing average Urals market price. Contracts concluded before 31 January 2026 with cargo offloaded by 16 April 2026 remain subject to the prior USD 47.60/bbl cap. The UK aligned with an equivalent reduction the same day.

On 15 January 2026 the UK Office of Financial Sanctions Implementation (OFSI), acting under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, amended the 'Oil Price Cap' General Licence (INT/2024/4423849) to lower the price cap on Russian seaborne crude oil from USD 47.60 to USD 44.10 per barrel, effective 23:01 on 31 January 2026. Contracts signed at the prior USD 47.60 cap before that time are subject to a wind-down period, remaining valid provided the oil is offloaded at the port of destination by 22:59 on 16 April 2026. The cut applies the six-monthly dynamic-adjustment formula (15% below the 22-week trailing average Urals price) and was announced in lockstep with the EU's equivalent Implementing Regulation 2026/124.

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 26 December 2025, Japan's Cabinet approved the FY2026 (Reiwa 8) national budget, which the Global Trade Alert database logs as including a "Capital Investment in Oil and Natural Gas Field Exploration and Asset Acquisition Projects" financial-grant/equity line administered by METI, effective with the fiscal year on 1 April 2026. This continues the government's long-standing equity-investment scheme -- run through JOGMEC (the Japan Organization for Metals and Energy Security) -- that co-funds Japanese companies' upstream oil and gas exploration, development, and M&A/asset-acquisition activity abroad. The FY2026 initial-budget allocation for this specific line is JPY 42.7 billion, down from JPY 56.3 billion in FY2025, though a JPY 19.7 billion supplementary appropriation lifts total FY2026 availability to roughly JPY 62.4 billion -- a modest net increase over FY2025 once the supplementary tranche is included.

The Mexican federal government published the Programa Sectorial de Energía 2025-2030 (PMSE) in the Diario Oficial de la Federación on 22 December 2025, establishing a binding five-year state-led energy-planning mandate for the Sheinbaum administration (2024-2030). The PMSE mandates a 54-46 state-to-private electricity generation mix, sets a 35 GW new clean-generation target by 2030 (13.6 GW from CFE + 22 GW from private/state/community projects), and formally supersedes the prior market-led Estrategia Nacional de Energía 2018-2032 and PRODESEN architecture. The Program is legally mandatory for all federal public administration entities including CFE, PEMEX, CENACE, and CENAGAS, operationalising the 2024 constitutional reform that restored CFE and PEMEX to strategic-sector status under Articles 27 and 28 of the Constitution.

On 20 December 2025, the African Export-Import Bank (Afreximbank) signed a USD 750 million dual-tranche senior secured reserve-based lending facility for Heirs Energies Limited, a Nigerian upstream oil and gas producer chaired by Tony O. Elumelu, at a ceremony in Abuja. Afreximbank acted as Mandated Lead Arranger, Facility Agent and Security Agent; the facility is intended to optimise Heirs Energies' capital structure and fund working capital as the company pursues its field development programme on OML 17, where it produces roughly 50,000 barrels per day plus associated and non-associated gas supplying three power plants that account for about 15% of Nigeria's installed electricity-generation capacity. Global Trade Alert logs the transaction as a state-linked loan intervention given Afreximbank's supranational, treaty-based public-development-finance mandate.

On December 18, 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated 29 shadow-fleet vessels and 17 vessel-management/shipping firms — plus Egyptian businessman Hatem Elsaid Farid Ibrahim Sakr and two of his UAE-registered companies (Red Sea Ship Management LLC and High Seas Petroleum LLC) — under Executive Order 13902 for operating in Iran's petroleum sector. The vessels, flagged across Palau, Panama, Cook Islands, Barbados, Jamaica and unknown registries, are said to have transported "hundreds of millions of dollars'" worth of Iranian crude oil, fuel oil, bitumen, naphtha and condensate to buyers in Asia. Treasury frames the action as part of a campaign that has sanctioned more than 180 vessels since President Trump resumed office in January 2025, implementing NSPM-2 maximum-pressure policy.

On 11 December 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated six shipping companies — registered in the Marshall Islands (4), British Virgin Islands (1), and the United Kingdom (1) — and their six crude-oil tankers as blocked property under Executive Order 13850 for operating in Venezuela's oil sector. The vessels (WHITE CRANE, KIARA M, MONIQUE, LATTAFA, H. CONSTANCE, and TAMIA) had loaded Venezuelan crude in September/October 2025 and allegedly used AIS spoofing and other deceptive shipping practices to evade detection. The same action separately designated four individuals — including two nephews of Cilia Flores (Nicolas Maduro's wife) under the counter-narcotics authority EO 14059, a former PDVSA official under EO 13692, and a Panamanian facilitator under EO 13850 — but the shipping-company/tanker designations are the action's primary trade-control component.

On 5 December 2025, at the opening of the 14th Practical Nigerian Content Forum, Nigeria's Nigerian Content Development and Monitoring Board (NCDMB) unveiled a USD 100 million Equity Investment Scheme to provide equity and quasi-equity financing to high-growth indigenous energy service companies, diversifying the income base of the Nigerian Content Development Fund (NCDF). NCDMB Executive Secretary Engr. Felix Omatsola Ogbe and Bank of Industry Managing Director Dr. Olasupo Olusi signed an MOU under which BOI will manage the scheme as a new product of the Nigerian Content Intervention Fund, with a single-obligor limit of USD 5 million per investment. NCDMB also reported Nigerian content (local-participation) attainment reached 61% by Q3 2025.

The Ivorian Council of Ministers adopted on 3 December 2025 the Politique Intégrée des Ressources Minérales et de l'Énergie (PIRME), a 15-year cross-sector extractive and energy industrial-policy strategy requiring CFA 38,000 billion (~USD 68bn) across three five-year phases to 2040. The policy targets doubling the mining-energy sector's GDP contribution from 7% (2022) to 14% by 2040, positioning it as the economy's second pillar after agriculture. Core mandates include a 50% local transformation target for gold, a 10 million-tonne iron-ore production target, a 500,000 bbl/day oil production target, 45% renewable energy integration, and a 38% reduction in energy-sector emissions — backed by national-content and value-addition requirements across mining, hydrocarbons, and electricity sub-sectors.

South Korea's Ministry of Economy and Finance announced its 2026 annual quota-tariff (할당관세) and flexible-tariff (탄력관세) operating plan on 2 December 2025, formalized via Presidential Decree No. 35944 (issued 30 December 2025, effective 1 January 2026) under Article 71 of the Customs Act. The plan sets reduced basic-tariff rates (0-3%, down from the 3% base rate) on roughly 58 imported goods through 31 December 2026, including LNG, LPG, and crude oil for LPG manufacturing (household heating relief), and newly adds steel and automotive-sector items exposed to US tariff measures plus recycling feedstock for critical-mineral supply-chain stabilization. A supplementary Presidential Decree No. 36237 (3 April 2026) later expanded crude-oil tariff-rate-quota eligibility to restructured petrochemical firms.

New Zealand's 33rd sanctions round under the Russia Sanctions Act 2022 designated 65 "shadow fleet" tanker vessels involved in transporting Russian-origin crude oil, together with seven entities and two individuals based in Russia, Belarus, North Korea and Iran that refine or transport Russian oil or facilitate oil-related payments. Designated parties are subject to asset freezes and prohibitions on the supply of services (including port access, insurance, chartering and cargo handling) by New Zealand persons. The measure targets the revenue chain funding Russia's war in Ukraine rather than imposing a new tariff or trade-flow control.

On 29 October 2025 the Swiss Federal Council amended the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), published as AS 2025 662, completing Switzerland's alignment with the remaining goods, finance and services elements of the EU's 18th Russia sanctions package (Council Regulation (EU) 2025/1494, 18 July 2025) and tightening the parallel Belarus regime. The amendment took effect 30 October 2025 and adds: an export ban covering additional structural-metal, general-purpose-machinery and machine-tool goods; an import ban on further petroleum-oil products and waste/scrap categories; and expanded controls on commercial transactions and investment instruments spanning financial services, investment banking, crude-petroleum trade and motor-vehicle/trailer goods. The Federal Department of Economic Affairs (WBF) had already taken over the measures within its own competence on 12 August 2025; this decision closes the remainder. In parallel, the Federal Council's asset-freeze annexes were extended to 14 individuals and 41 companies/organizations.

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 October 22, 2025, the US Treasury's Office of Foreign Assets Control (OFAC) added Open Joint Stock Company Rosneft Oil Company ("Rosneft") and Lukoil OAO ("Lukoil") — together with dozens of named Russia-based subsidiaries — to the Specially Designated Nationals (SDN) List under Executive Order 14024 for "operating or having operated in the energy sector of the Russian Federation economy." It is the first US designation of Russia's two largest integrated oil majors since the 2022 invasion-era sanctions architecture began. Under OFAC's 50% Rule, the blocking extends automatically to all entities owned 50% or more, directly or indirectly, by Rosneft or Lukoil — capturing a sprawling global subsidiary network including Lukoil retail/refining assets in Belgium, Netherlands, Bulgaria, Romania, Italy, Finland, the West Qurna-2 upstream stake in Iraq, and Lukoil Americas. Rosneft and Lukoil together account for roughly half of Russian crude exports (~5 mb/d combined production) and Lukoil holds a ~9% European retail-fuel market share. OFAC simultaneously issued General License 124 (Caspian Pipeline Consortium / Tengizchevroil / Karachaganak Kazakhstan-pipeline carve-out, no expiry), General License 125 (Lukoil retail service stations outside Russia, wind-down to November 21, 2025), General License 126 (general wind-down to November 21, 2025) and General License 127 (debt/equity divestment and derivatives wind-down to November 21, 2025). GL 131 (issued November 14, 2025) opened a divestment window for Lukoil International GmbH; subsequent GL 134/134A/134B extended cargo-offload authorisations through April–May 2026. The action was coordinated same-day with UK OFSI Rosneft/Lukoil designations and the EU's 19th Russia sanctions package adopted October 23, 2025 — the first major US-led Russia-energy escalation under the second Trump administration.

On 15 October 2025 the UK Foreign, Commonwealth & Development Office, acting under the Russia (Sanctions) (EU Exit) Regulations 2019, designated 39 entities and specified 51 vessels — including, for the first time, Russia's two largest integrated oil majors PJSC Rosneft Oil Company and PJSC Oil Company Lukoil — for supporting Russia's energy, defence and financial sectors. 51 vessels (44 identified as "shadow fleet" tankers) were specified for transporting Russian crude oil and LNG in evasion of the G7 price cap. The package also introduced a ban on importing oil products refined in a third country from Russian-origin crude, closing a refined-product loophole in the price-cap regime.

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 30 September 2025 Japan Bank for International Cooperation (JBIC) signed a facility agreement providing up to USD 1.8 billion (JBIC's portion) to Abu Dhabi National Oil Company (ADNOC), co-financed alongside Mizuho Bank (agent) and HSBC's Tokyo branch for a total facility of USD 3 billion. The loan is explicitly structured to support "stable imports of crude oil by Japanese companies" and is the seventh JBIC loan extended to ADNOC for this purpose. A companion MOU signed 4 November 2025 at ADIPEC 2025 broadens the JBIC-ADNOC partnership into downstream energy-transition sectors (hydrogen, ammonia, chemicals).

Australia aligned with the EU/G7's 18th-package price cap by lowering its own cap on Russian-origin crude oil from USD 60 to USD 47.60 per barrel, and designated 95 additional "shadow fleet" tanker vessels used to circumvent the cap, under the Autonomous Sanctions Regulations 2011. Foreign Minister Penny Wong framed the measure as intended to depress the market value of Russian crude and reduce war-financing oil revenue. The listings bring Australia's cumulative shadow-fleet vessel designations to over 150 since June 2025 and its total Russia-related sanctions actions since 2022 to roughly 1,600.

The US Treasury's Office of Foreign Assets Control designated two Iranian financial facilitators — Alireza Derakhshan and Arash Estaki Alivand — along with more than a dozen Hong Kong- and UAE-based individuals and entities for operating a shadow-banking network that laundered proceeds from Iranian oil sales through front companies and cryptocurrency. The designated addresses account for over $600 million in total inflows, including more than $100 million in cryptocurrency purchases tied to oil sales between 2023 and 2025. Proceeds are alleged to benefit the IRGC-Qods Force and Iran's Ministry of Defense and Armed Forces Logistics (MODAFL). This is the second round of OFAC sanctions targeting Iran's shadow-banking infrastructure since National Security Presidential Memorandum 2 (NSPM-2) directed a maximum-pressure campaign on Iran in February 2025.

New Zealand's 32nd sanctions round under the Russia Sanctions Act 2022 (Russia Sanctions Amendment Regulations (No 4) 2025, SL 2025/195) lowered the price cap on Russian-origin crude oil (HS 2709) from US$60/bbl to US$47.60/bbl, a roughly 21% cut, aligning New Zealand with the EU, UK and Canada's most recent price-cap reductions. The same instrument designated 19 individuals and entities plus 19 vessels, including Russia's GRU cyber unit 29155 (implicated in malware attacks on Ukrainian government networks), actors involved in chemical-weapons use and disinformation, additional "shadow fleet" tankers, alternative payment providers, and third-country facilitators based in North Korea and Iran supporting Russia's war effort.

On 2 September 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated Waleed Khaled Hameed al-Samarra'i, a dual Iraqi/St Kitts-and-Nevis citizen, along with his UAE-based shipping manager Babylon and five Marshall Islands-registered shell companies (Tryfo Navigation, Keely Shiptrade, Odiar Management, Panarea Marine, Topsail Shipholding) that hold registered ownership of nine Liberia-flagged tankers (ADENA, LILIANA, CAMILLA, DELFINA, BIANCA, ROBERTA, ALEXANDRA, BELLAGIO, PAOLA). The network blends Iranian crude with Iraqi oil via ship-to-ship transfers in the Arabian Gulf and at Iraqi ports, then markets the blend as solely Iraqi-origin to evade US sanctions, generating hundreds of millions of dollars for the Iranian regime and al-Samarra'i. The action was taken pursuant to Executive Order 13902 and blocks all US property and interests of the designated individual, entities and vessels.

On 12 August 2025 the Swiss Federal Department of Economic Affairs, Education and Research (WBF) amended the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), published as AS 2025 497, adopting — within its own delegated competence and ahead of the full Federal Council decision — an interim tranche of measures aligning Switzerland with the EU's 18th Russia sanctions package (Council Regulation (EU) 2025/1494, 18 July 2025). The amendment lowers the Russian-crude price cap and updates the associated Annex 28 price-threshold table, extends export prohibitions on transport services, adds port-access restrictions covering 105 additional shadow-fleet vessels, and widens controls on commercial transactions and investment instruments for Russian financial institutions. It also extends asset-freeze listings to entities in China, Hong Kong, Singapore, Mauritius, Azerbaijan, India and the UAE implicated in circumvention. The measure took effect 12 August 2025. The Federal Council closed out the remaining goods, finance and services elements of the 18th package on 29 October 2025 (see responds_to).

On 4 August 2025, the African Export-Import Bank (Afreximbank) signed a USD 1.35 billion financing facility in favour of Dangote Industries Limited (DIL), acting as Mandated Lead Arranger within a larger approximately USD 4 billion syndicated facility. The financing refinances capital expended on constructing the Dangote Petroleum Refinery and Petrochemicals Complex — the world's largest single-train refinery at 650,000 barrels per day — alleviating initial operating expenditure and strengthening DIL's balance sheet. Global Trade Alert logs the transaction as a state-linked loan intervention given Afreximbank's supranational, treaty-based public-development-finance mandate.

On 30 July 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated more than 50 individuals and entities and identified more than 50 vessels belonging to the shipping empire of Mohammad Hossein Shamkhani, son of Ali Shamkhani, a top political adviser to Iran's Supreme Leader. Treasury described the action — over 115 sanctions in total — as its largest Iran-related action since 2018. The network launders billions of dollars from sales of Iranian and Russian crude oil and petroleum products (mostly to buyers in China) through vessels and front companies registered across the UAE, Hong Kong, India, Cyprus, Panama, Romania, China, Liberia, the Marshall Islands and Seychelles. Concurrently, the State Department designated 20 entities and identified 10 vessels under E.O. 13846 and E.O. 13902 for trading and transporting Iranian petroleum and petrochemical products.

On 21 July 2025 the UK announced 137 new sanctions designations under its Russia regime, targeting 135 oil tankers identified as part of Russia's "shadow fleet" plus two enabling companies: Litasco Middle East DMCC (a Dubai-based trading arm linked to Lukoil, sanctioned for moving Russian oil on shadow-fleet vessels) and Intershipping Services LLC (sanctioned for registering shadow-fleet vessels under the Gabonese flag). FCDO states the targeted vessels have carried an estimated $24 billion of cargo since the start of 2024, and that Intershipping's flag-registration activity has enabled up to $10 billion/year in Russian state-linked shipping. The action was announced alongside a further lowering of the UK/EU Crude Oil Price Cap and runs as a companion measure to the EU's 18th sanctions package (Council Regulation 2025/1494), adopted three days earlier.

On 18 July 2025, the Council of the European Union adopted the 18th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/1494 amending Regulation 833/2014 (sectoral measures), Council Implementing Regulation (EU) 2025/1476 implementing Regulation 269/2014 (asset-freeze listings), Council Decision (CFSP) 2025/1495 (vessel listings), and Council Regulation (EU) 2025/1472 (parallel Belarus measures). The package is the largest energy-sector escalation since 2022 and pivots from new-perimeter creation toward enforcement and circumvention closure. Headline measures: (i) the Russian-crude price cap is lowered from USD 60 to USD 47.6 per barrel with a new automatic dynamic mechanism re-indexing the cap to global oil prices every six months at a 15 % discount to the 22-week trailing average (effective 3 Sep 2025, with a transitional exemption to 18 Oct 2025 for pre-20 Jul 2025 contracts compliant with the prior cap); (ii) full transaction ban extended to 22 additional Russian banks, bringing the total cut off from the EU financial system to 45; transaction ban extended to third-country financial institutions and crypto-asset service providers facilitating circumvention; (iii) full transaction ban on Nord Stream 1 and Nord Stream 2 pipelines; (iv) import ban on refined oil products derived from Russian crude processed in third countries; (v) 105 additional vessels added to the shadow-fleet port-access ban (cumulative total 444); (vi) 26 new entities added to Annex IV military end-user list (15 Russian + 11 from China/Hong Kong/Turkey); (vii) Council Implementing Regulation 2025/1476 lists 14 individuals + 41 entities under asset-freeze, including a major Indian refinery (Nayara Energy, part-owned by Rosneft), three Chinese suppliers of battlefield goods, shadow-fleet operators, and entities involved in the deportation of Ukrainian children; (viii) parallel Belarus complementary measures via Regulation 2025/1472. Wind-down periods vary: 90 days for oil-price-cap contracts; banking-software wind-down to 30 Sep 2025; trade-goods wind-downs Oct 2025–Jan 2026 by category. Entry into force on 19 July 2025 (day following publication in the Official Journal), except for measures with explicit deferred application dates.

Minister of Trade Regulation No. 20 of 2025, signed by Minister Budi Santoso on 30 June 2025 and effective 29 August 2025 (60 days after promulgation), reorganises Indonesia's import regime for chemicals, Hazardous Materials (B2), and a defined set of mining and energy inputs. The regulation revokes Permendag 8/2024 and requires holders of designated importer status (Importir Terdaftar / Importir Produsen) to secure an Import Approval (Persetujuan Impor) plus a post-arrival Surveyor Report (Laporan Surveyor) for an eleven-cluster commodity bundle including lubricant raw materials, cement clinker and cement, rough diamonds, non-pharmaceutical precursors, crude oil and natural gas, nitrocellulose, commercial-industrial explosives, ozone-depleting substances, hydrofluorocarbons, B2, and certain other chemicals (BKT). It is one of nine commodity-cluster Permendags issued the same day under the Prabowo administration's umbrella import-policy deregulation package.

Mozambique's Ministry of Mineral Resources and Energy (MIREME) published a comprehensive revision of the 2014 Petroleum Law (Lei n.º 21/2014) in June 2025, tabled before the Assembleia da República for debate on 7 May 2026. The revision mandates a minimum 25% domestic-market quota for all oil, gas, and LNG produced under concessions (exclusively for national consumption), requires 100% of condensate output to be allocated domestically, and introduces idle-block penalty charges for concessionaires that fail to develop assigned blocks within prescribed periods. It also elevates the Instituto Nacional de Petróleo (INP) to full Regulatory Authority status with inspection and sanctioning powers, and establishes a mandatory minimum state Participating Interest with a free-carry obligation through to commercial production.

President Bola Ahmed Tinubu signed the Upstream Petroleum Operations (Cost Efficiency Incentives) Order, 2025 on 29 May 2025, introducing a performance-based tax-credit framework for upstream oil and gas operators who beat NUPRC-set Unit Operating Cost benchmarks. Eligible lessees, licensees, and PSC contractors receive tax credits capped at 20% of their annual petroleum tax liability per licence area, applied against Petroleum Profits Tax, Hydrocarbon Tax, or Companies Income Tax. The Nigerian Upstream Petroleum Regulatory Commission (NUPRC) conducts annual terrain-specific (onshore, shallow-water, deep-offshore) Unit Operating Cost benchmarking, and the Federal Inland Revenue Service (FIRS) co-administers with claw-back provisions for non-compliance; the regime runs through 31 May 2035.

On 20 May 2025, the Council of the European Union adopted the 17th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/932 amending Regulation 833/2014 (sectoral measures) and Council Implementing Regulation (EU) 2025/933 implementing Regulation 269/2014 (asset-freeze listings). Sectoral measures include the largest single-package expansion of the shadow-fleet port-access ban (additional vessel listings layered on top of the 153 designations carried over from the 16th package), the addition of 31 entities — including third-country (Chinese, Turkish, UAE, Hong Kong) firms — to the Annex IV list of military end-users barred from receiving dual-use and critical industry goods (covering chemical precursors used in missile propellants and spare parts for high-precision machine tools), and reinforced anti-circumvention "no-Russia" clause obligations on EU exporters. Council Implementing Regulation (EU) 2025/933 imposes asset freezes on 17 additional individuals and 58 additional entities, including shadow-fleet vessels and operators, a major Russian oil company, Russian military/defence-sector firms, and persons involved in the looting of Ukrainian cultural heritage. Parallel hybrid-threat, human-rights, and chemical-weapons designations were adopted under separate horizontal regimes on the same day. The Council noted EU shadow-fleet and oil-price-cap measures had reduced Russian revenues by approximately EUR 38 billion since introduction. Entry into force on 21 May 2025 (day following publication in the Official Journal).

On 13 May 2025, the US Treasury's Office of Foreign Assets Control designated nearly two dozen firms and individuals — including Hong Kong-based intermediary Star Energy International Limited — for operating in Iran's illicit international oil trade on behalf of Sepehr Energy Jahan Nama Pars Company (Sepehr Energy), the Tehran-based oil-sales arm of Iran's Armed Forces General Staff (AFGS). The designated network spans commercial intermediaries and shipping counterparties across China, Hong Kong and Singapore, the last a hub for ship-to-ship transfers of Iranian-origin crude. Designations were made under counter-terrorism (SDGT) and Iran Financial Sanctions Regulations (IFSR) authorities as part of the administration's maximum-pressure campaign to cut off military and IRGC-linked revenue from Iran's oil exports.

On 8 May 2025, the US Treasury's Office of Foreign Assets Control designated China-based "teapot" refinery Hebei Xinhai Chemical Group Co., Ltd. and its Singapore-based broker subsidiary Xing AO Energy PTE. LTD., three firms tied to a Dongying Port (Shandong) terminal that has received Iranian crude from shadow-fleet tankers, and six Hong Kong-, UK-, and Marshall Islands-owned shadow-fleet vessels (STAR TWINKLE 6, LAMD, SKADI, BIG MAG, IMPALAS, THANE) plus their owning shipping companies and two vessel captains. It is OFAC's third action against an Iranian-oil teapot refinery and its first targeting Shandong port terminal operators, taken under E.O. 13902 (Iran petroleum/ petrochemical sector) and E.O. 13846 (NIOC support) as part of the administration's NSPM-2 maximum-pressure campaign.