Industrial Policy & Trade Monitor· 2667 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 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.

The UAE and United States signed a bilateral Framework on Securing Supply in the Mining and Processing of Critical Minerals and Rare Earths on 4 February 2026, on the sidelines of the 2026 US Critical Minerals Ministerial in Washington DC. The framework coordinates a joint UAE-US approach across mining, separation, processing, recycling, and downstream activities, leveraging UAE strategic reserves alongside US industrial demand and stockpiling infrastructure. Both parties committed to mobilise public and private investment via financing, guarantees, equity investments, offtake arrangements, insurance, and regulatory facilitation, and to streamline permitting and protect supply chains from non-market practices. Within six months, both parties intend to identify priority projects for financing, and to cooperate on recycling technology, geological mapping, and national security asset-review procedures.

The United Kingdom and the United States signed a non-binding Memorandum of Understanding on critical minerals in Washington DC on 4 February 2026 at the 2026 US Critical Minerals Ministerial. The MOU commits both Participants to intensify cooperative efforts to accelerate the secure supply of critical minerals and rare earths for defence manufacturing and advanced technologies, mobilising government financial tools (guarantees, loans, equity investments, offtake arrangements, insurance) and streamlining permitting timelines. On the UK side, the Department for Business and Trade committed up to £50 million in new funding to support critical mineral projects following the 2025 Spending Review. The instrument also includes a commitment to cooperate on price-floor mechanisms — the first bilateral price-floor cooperation filing on the IPTM register — as part of a broader US-led plurilateral initiative to establish reference prices countering non-market overproduction.

On 2 February 2026 the Export-Import Bank of the United States (EXIM) Board approved a Direct Loan of up to USD 10 billion to an independently governed public-private partnership establishing the U.S. Strategic Critical Minerals Reserve ("Project Vault"), alongside nearly USD 2 billion of private-sector investment for an envelope of approximately USD 12 billion. The reserve will physically stockpile the 60 minerals on the USGS 2025 Critical Minerals List across multiple US storage facilities, with participating original equipment manufacturers (Clarios, GE Vernova, Western Digital, Boeing) committing to specific volumes and grades and trading partners (Hartree Partners, Mercuria Americas, Traxys) handling sourcing. EXIM characterises the transaction as the largest single financing in its 92-year history and the first use of EXIM authority as the financing vehicle for a domestic strategic-minerals stockpile rather than for export-credit insurance abroad.

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.

Law No. 4 of 15 January 2026 (Gazzetta Ufficiale n. 15 of 20 January 2026, in force 21 January 2026) converted with amendments Decree-Law No. 175 of 21 November 2025 ("Transizione 5.0"). During parliamentary conversion the Camera dei Deputati inserted a new Article 2-bis that materially expands Italy's Golden Power foreign-investment screening regime (DL 21/2012) into the financial, credit, and insurance sectors — the first explicit statutory inclusion of banking and insurance qualifying-holding transactions inside the Golden Power perimeter. The amendment introduces "national economic and financial security" as a public-order criterion alongside the traditional security and public-order profiles, and conditions exercise of special powers in the financial sector on the prior conclusion of pending European prudential and competition proceedings (ECB / EIOPA / EU Commission).

On 12 December 2025 the Swiss Federal Council adopted the first tranche of listings aligning with the EU's 19th Russia sanctions package (Council Regulation (EU) 2025/2033, 23 October 2025), amending the Ordinance on Measures in Connection with the Situation in Ukraine and the Belarus Ordinance with effect from 13 December 2025. The decision adds asset freezes and entry/transit bans for 22 natural persons and 42 entities tied to Russia's military-industrial complex, energy sector and shadow-fleet vessel management; extends purchase/sale/insurance bans to over 100 additional tankers; imposes transaction restrictions on 5 Russian banks and 4 Russian-bank branches in Belarus and Kazakhstan for use of specialised financial-messaging services; sanctions Chinese and Hong Kong trading companies and refineries implicated in circumventing the G7 oil price cap; and designates 5 Belarusian persons linked to military-industrial activities. Divestment-exemption deadlines for Swiss persons winding down Russian holdings are extended to end-2026. This is a partial, listings-only tranche — the more substantive measures of the EU's 19th package (Russian LNG import ban, crypto-services prohibition, AI/HPC service bans) were not adopted until the Federal Council's follow-on decision of 25 February 2026.

KfW IPEX-Bank, the project- and export-finance arm of Germany's state-owned development bank KfW, announced on 28 November 2025 that it structured earmarked, unsecured 19-year corporate financing in the "mid-three-digit-million" British pound range for MVV Energie AG's Medworth thermal waste treatment (energy-from-waste) plant under construction in Wisbech, Cambridgeshire, England — MVV's fourth UK plant and, at roughly EUR 500 million in total project investment, the largest single investment in MVV's history. Swiss Export Risk Insurance (SERV) covers the majority of the construction-phase buyer credit for the first time in an MVV financing. Global Trade Alert separately logs the transaction as a "red"-flagged state-linked financial-assistance-in-a- foreign-market intervention (state act 95518 / intervention 151093).

On 24 November 2025, six Beijing municipal departments — the Bureau of Economy and Information Technology, Development and Reform Commission, Science and Technology Commission, Health Commission, Drug Administration and Medical Insurance Bureau — jointly issued Notice 京经信发〔2025〕50号 ("Several Measures to Promote High-Quality Development of the Beijing Medical Device Industry"), effective immediately through 31 December 2028. The 15-measure package subsidises the full medical-device value chain: early-stage innovation (up to RMB 1m per project), product approval/launch (up to RMB 2m per product, RMB 10m annual enterprise cap), industrial-park and public-service infrastructure construction (up to 50% of investment, capped at RMB 50m), supply-chain-resilience R&D for critical components/materials (up to 30% of investment, capped at RMB 30m), AI-diagnostic-model development (up to RMB 30m), smart-factory digitalisation (up to 30% of investment, capped at RMB 30m per project), and international regulatory approval/market entry (up to RMB 1m per product, RMB 3m annual cap; up to RMB 10m for introducing overseas products to China).

On 18 November 2025, the European Supervisory Authorities (EBA, ESMA, and EIOPA) jointly designated 19 Critical ICT Third-Party Providers (CTPPs) under DORA Article 31, with immediate effect — the first-ever exercise of direct EU financial-regulator supervision over hyperscale cloud and infrastructure providers. The designated entities include Amazon Web Services, Microsoft Azure, Google Cloud, Deutsche Telekom, Oracle, SAP, IBM, Bloomberg LP, London Stock Exchange Group (LSEG), Tata Consultancy Services, and Orange, among others. Designation triggers direct oversight by a lead ESA (EBA for banking-critical, ESMA for capital-markets-critical, EIOPA for insurance-critical) via Joint Examination Teams (JETs), with powers to conduct investigations, carry out on-site inspections, and impose fines of up to 1% of average daily worldwide turnover per day for non-compliance.

On 4 November 2025 Korea's Ministry of Trade, Industry and Energy (MOTIE) launched a new "steel export supply-chain strengthening guarantee" product as part of a broader steel-industry advancement plan. POSCO and the Industrial Bank of Korea (IBK) jointly seeded KRW 20 billion, on which the Korea Trade Insurance Corporation (K-Sure) built a KRW 400 billion (~USD 274 million) preferential guarantee program for small and mid-sized steel exporters and steel-derivative producers hit by tightening trade barriers abroad, chiefly the US Section 232 steel tariff regime. Benefits include interest-rate cuts of up to 2 percentage points, guarantee-period extension from 1 to 3 years, a guarantee-fee cut from 1% to 0.7%, and expanded guarantee limits.

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.

Japan Bank for International Cooperation (JBIC), Japan's state export-credit and outbound-investment finance institution, signed a loan agreement on 2025-10-28 providing up to USD 85.75 million to ALBRAS - Alumínio Brasileiro S.A., an aluminum smelter in Pará, Brazil, co-financed with MUFG Bank (insured by Nippon Export and Investment Insurance, NEXI). The facility funds capital investment to address aging equipment and sustain ALBRAS's production capacity. JBIC explicitly frames the loan as securing a long-term stable supply of low-carbon primary aluminum for Japan, which relies entirely on imports for the metal.

On 27 October 2025, during the Trump-Takaichi Tokyo summit, the United States and Japan announced the "Framework for Securing the Supply of Critical Minerals and Rare Earths through Mining and Processing", signed by President Donald J. Trump and Prime Minister Sanae Takaichi on 28 October 2025. The non-binding framework establishes a US-Japan Critical Minerals Supply Security Rapid Response Group co-led by the US Secretary of Energy and the Japanese METI Minister; commits both governments to provide financial support to selected mining and processing projects within six months via grants, guarantees, loans, equity, offtake arrangements, and insurance — mobilising DFC + EXIM (US side) with JOGMEC + JBIC (Japan side); develops a "mutually complementary stockpiling arrangement" leveraging existing national systems; and schedules a Mining, Minerals and Metals Investment Ministerial within 180 days. The framework was subsequently operationalised through the 19 March 2026 "United States-Japan Action Plan for Critical Minerals Supply Chain Resilience" jointly issued by USTR and METI.

Five Tianhe District (Guangzhou) government bureaus jointly issued Notice 穗天发改规字〔2025〕3号 on 2025-10-16, promulgating "Several Policy Measures to Accelerate High-Quality Development of the Low-Altitude Economy and Aerospace in Tianhe District," effective 30 days after publication (2025-11-19) through 2027-12-31. The package caps district-scale subsidy tracks covering industrial-park and professional-building recognition (up to RMB 1 million per operator), core-technology R&D grants (up to RMB 1 million/year, scaled by enterprise revenue band), airworthiness-certification support (up to RMB 2 million per enterprise/year), low-altitude logistics and eVTOL route operating subsidies (up to RMB 3 million annual pools each), talent incentives (RMB 100,000/person/year, capped at a RMB 10 million pool), vocational training, and insurance support. Global Trade Alert classifies the measure as state aid with a "certainly harmful" (Red) rating.

On 17 October 2025 Türkiye's Ministry of Industry and Technology opened the "HIT-Data Centre" call, a USD 1.5 billion support tranche under the HIT-30 High Technology Investment Programme (see `2024-07-26-turkiye-hit-30-high-technology-investment-programme`), targeting data-centre facilities of at least 30 MW IT capacity with at least 50% AI-compatible hardware and a Power Usage Effectiveness (PUE) of 1.4 or lower. The call was announced alongside three parallel HIT-30 sector calls — a USD 1.6 billion "HIT-AI" call (see `2025-10-17-turkiye-hit-ai-cloud-infrastructure-call`), a USD 300 million "HIT-Quantum" call, and a USD 1 billion "HIT-Industrial Robot" call — and offers the same tax, grant, financing, employment, and market-development instrument stack used across the HIT-30 programme. Global Trade Alert logs this single government call as two separate "interventions" (tax/social insurance relief and unspecified state aid) under state act 95013.

On 17 October 2025 Türkiye's Ministry of Industry and Technology opened the "HIT-Industrial Robot" call, a USD 1 billion support tranche under the HIT-30 High Technology Investment Programme (see `2024-07-26-turkiye-hit-30-high-technology-investment-programme`), targeting manufacturers that commit to a minimum annual production capacity of 5,000 industrial robots and localisation of critical components (servo motors, reducers/gearboxes, servo drives), plus supporting R&D-centre buildout. The call was announced alongside three parallel HIT-30 sector calls — a USD 1.6 billion "HIT-AI" call (see `2025-10-17-turkiye-hit-ai-cloud-infrastructure-call`), a USD 1.5 billion "HIT-Data Centre" call (see `2025-10-17-turkiye-hit-data-centre-call`), and a USD 300 million "HIT-Quantum" call — and offers the same tax, grant, financing, employment, and market-development instrument stack used across the HIT-30 programme. Global Trade Alert logs this single government call as two separate "interventions" (state loan and tax/social-insurance relief) under state act 95018.

On 17 October 2025 Türkiye's Ministry of Industry and Technology opened the "HIT-Quantum" call, a USD 300 million support tranche under the HIT-30 High Technology Investment Programme (see `2024-07-26-turkiye-hit-30-high-technology-investment-programme`), aimed at building high-capacity infrastructure for quantum computing services, a scalable quantum hardware/software ecosystem for research centres, universities and the private sector, and skilled-workforce development. The call was announced alongside three parallel HIT-30 sector calls — a USD 1.6 billion "HIT-AI" call (see `2025-10-17-turkiye-hit-ai-cloud-infrastructure-call`), a USD 1.5 billion "HIT-Data Centre" call (see `2025-10-17-turkiye-hit-data-centre-call`), and a USD 1 billion "HIT-Industrial Robot" call (see `2025-10-17-turkiye-hit-industrial-robot-call`). Global Trade Alert logs this single government call as three separate "interventions" (financial grant, state loan, and tax/social-insurance relief) under state act 95017.

On 9 October 2025 the Shandong Provincial People's Government General Office issued Notice 鲁政办字〔2025〕129号, promulgating "Several Measures to Accelerate High-Quality Development of Shandong's Commercial Aerospace Industry," effective on issuance through 31 December 2027. The package targets three sub-sectors — launch vehicles, satellite manufacturing/applications, and aerospace supporting industries — with a province-wide goal of reaching an annual production capacity of 100 commercial rocket launches and 150 commercial satellites, and a commercial-aerospace industry scale of RMB 50 billion (500亿元), by 2027. Concrete subsidy instruments include a sea-launch insurance rebate (up to 35% of "launch insurance" and "third-party liability insurance" premiums, capped at RMB 3 million per project) for operators launching from the Yantai Dongfang Aerospace Port sea-launch platform, a bounty of up to RMB 1 million per product for satellite-application AI models that pass third-party evaluation, and a computing-power subsidy of up to 5% of contract value (capped at RMB 5 million per firm) for satellite applications that procure significant compute. The measures also direct Yantai to anchor sea-launch and integrated manufacturing, Jinan and Tai'an to build out rocket/satellite manufacturing and constellation operations, and Qingdao to specialise in satellite-application clusters and Belt-and-Road-facing services.

Japan lowered its price cap on Russian-origin crude oil from USD 60 to USD 47.60 per barrel, effective for contracts concluded on or after 12 September 2025, aligning with the EU's July 2025 cut under its 18th sanctions package. The measure bars Japanese entities from importing, or providing shipping, insurance, financing or other services for, Russian crude priced above the new cap. In the same package Japan added 47 Russian entities and 9 individuals, 6 Crimea/Donbas-linked persons and entities, and 3 third-country entities to its asset-freeze list (transactions now require Ministry of Finance approval), and imposed export prohibitions on 2 Russian entities and 9 entities in third countries. Japan's own Russian crude imports are minimal (~0.1% of total crude imports, Jan-Jul 2025), so the measure is primarily a coalition-alignment and shipping/insurance-chokepoint action rather than a material change to Japan's own energy sourcing.

The Hainan Provincial People's Government General Office issued "Several Policy Measures of Hainan Province for Further Supporting High-Quality Development of the Biopharmaceutical Industry" (Qiong Fu Ban [2025] No. 38) on 2025-08-14, effective 2025-09-13 for a three-year term. The package disburses provincial subsidies across the full biopharma value chain — R&D-stage grants, national centralized-procurement awards, international-certification bonuses, platform-investment reimbursement, and traditional-Chinese-medicine insurance-listing awards — leveraging Hainan Free Trade Port status to build a regional biomedical industry cluster.

The Henan Provincial People's Government issued Yuzheng [2025] No. 18 (豫政〔2025〕18号), "Several Policy Measures to Support Enterprises in Reducing Costs and Increasing Efficiency" (河南省支持企业降本增效若干政策 措施), on 2025-08-04, effective on issuance. The package is a horizontal, cross-sector cost-reduction bundle spanning ten cost categories: R&D subsidies of up to 30% of investment (capped at RMB 5-20 million per project depending on program), equipment-renewal loan interest subsidies and technical-transformation grants (15-20% of investment, capped at RMB 5-10 million), labor-cost relief (unemployment-insurance rate held at 1%, workers'-comp rate cut 20%, unemployment-insurance stabilization rebates of 30-60% through end-2025), financing-cost relief (RMB 160 billion 2025 lending target to tech enterprises, up to RMB 4 million in start-up guarantee loans), logistics-cost relief (toll exemptions for hydrogen trucks and 30% toll discounts for electric trucks through 2025-12-31, RMB 10,000-140,000 scrap-and-renew subsidies for aging trucks), and import/export-cost relief (tariff and quick-approval facilitation for integrated-circuit and advanced-equipment imports, up to 70% subsidy on overseas certification costs).

Korea Trade Insurance Corporation (K-SURE), a Korean government export-credit agency, announced on 4 August 2025 a US$1bn (~KRW 1.4tn) financial guarantee backing LG Chem's construction of a cathode material plant in Clarksville, Montgomery County, Tennessee. The facility is being built in a first phase for roughly KRW 2tn, with 60,000 tons/year of NCMA (nickel-cobalt-manganese- aluminum) cathode capacity — described by K-SURE as the largest cathode material production line in the United States, sufficient for around 600,000 electric vehicles. K-SURE stated this is the first US investment guarantee issued following the Korea-US tariff negotiation, under which Seoul agreed to channel a large bilateral investment package into the United States; the guarantee lets LG Chem access lower-cost, longer-tenor financing from global banks for the project.

The Heilongjiang Provincial People's Government General Office issued Hei Zheng Ban Gui [2025] No. 5 (黑政办规〔2025〕5号), "Several Policy Measures to Support the High-Quality Development of the High-End Intelligent Agricultural Machinery Equipment Industry" (黑龙江省支持高端 智能农机装备产业高质量发展若干政策措施), on 2025-08-01, effective on issuance through 2027-12-31. The 20-measure package covers R&D subsidies, capital-expenditure grants for major projects, sales-revenue rebates, insurance-premium compensation, and loan interest subsidies for agricultural-machinery manufacturers operating in the province.

On 31 July 2025 the General Office of the Guangdong Provincial Government issued Yue Ban Han [2025] No. 231, promulgating 21 policy measures across seven categories to accelerate commercial space development in the province through 2028 (published 19 August 2025; in force through 31 December 2028). The package funds satellite-constellation and ground-station buildout (10% capex subsidy, capped at RMB 2m per node and RMB 10m per firm annually), rocket/satellite equipment subsidies (up to 30% of unit sale price, capped at RMB 7-9m per set depending on catalog tier), up to 50% matching funds for qualifying national R&D programs, a 100% pre-tax R&D expense deduction, industrial-park investment rebates (up to 2% of new fixed-asset investment, paid to municipal governments), government procurement preference for demonstration applications, and dedicated investment funds and insurance-premium subsidies for launch and satellite-operator risk. It implements an earlier provincial action plan (2024-2028) and predates China's national CNSA commercial-space action plan (25 November 2025) by four months.

India and the UK signed the Comprehensive Economic and Trade Agreement (CETA) on 24 July 2025 in Chequers, with Prime Ministers Modi and Starmer presiding. The agreement grants duty-free access on 99% of Indian exports to the UK (textiles, apparel, footwear, auto components, engineering goods and chemicals), and reduces Indian tariffs on UK goods covering ~90% of tariff lines: Scotch whisky duties drop from 150% to 75% on day one and taper to 40% over ten years; high-end UK car tariffs fall from ~110% to 10% under a quota; UK MFN access on a wide industrial-goods envelope. A Double Contribution Convention exempts Indian secondees from UK National Insurance for three years. Bilateral trade currently ~£42 bn / USD 56 bn per year, with the parties targeting doubling by 2030. UK ratification under the Constitutional Reform and Governance Act 2010 (CRaG) ran from January 2026, with the 21-sitting-day scrutiny period concluding 5 March 2026. Entry into force was delayed from the originally targeted May 2026 date and is now confirmed for July 15, 2026 following a UK Prime Minister announcement at the G7 Évian summit sidelines on June 17, 2026. The confirmed EIF covers 64% of UK exports (£1.9bn) duty-free immediately, with an additional £25.5bn/year in projected additional bilateral trade.

The Joint Committee of the European Supervisory Authorities (EBA, EIOPA, ESMA) published the Guide on DORA Oversight Activities (JC 2025 29) on 15 July 2025, the definitive operational description of how the ESAs will supervise Critical ICT Third-Party Providers (CTPPs) designated under DORA Art. 31. The guide establishes the governance of Joint Examination Teams (JETs), the oversight examination lifecycle (planning, risk assessment, binding recommendations, follow-up), penalty processes of up to 1% of average daily worldwide turnover per day of breach (DORA Art. 35(6)), and lead-overseer assignments (EBA for banking, ESMA for capital markets, EIOPA for insurance). It is authoritative ESA interpretive guidance, not legally binding per se, but constitutes the supervisory playbook CTPPs and their dependent financial entities must plan against.

On 9 July 2025 USDA Secretary Brooke L. Rollins announced the Supplemental Disaster Relief Program (SDRP), making USD 16 billion in congressionally mandated assistance available to producers who suffered eligible crop losses from qualifying natural disasters in 2023 and 2024. The Farm Service Agency is delivering the assistance in two stages: Stage One (opened 10 July 2025) covers producers who already received crop insurance or Noninsured Crop Disaster Assistance Program payments for the affected years; Stage Two, covering shallow and uninsured losses, was slated to begin in early fall 2025. Eligible disasters include wildfires, hurricanes, floods, derechos, excessive heat, tornadoes, winter storms, freeze events, smoke exposure, excessive moisture, and qualifying drought, across row crops, specialty crops, and perennial crops.

Brazil's national development bank BNDES approved a BRL 100 million (~USD 18 million) financing package for BRQ Digital Solutions, funded through the BNDES Mais Inovação program, to build 17 technical accelerators for the company's proprietary generative-AI platform "Fusion BRQ." The operation is aligned with Mission 4 (Digital Transformation) of Nova Indústria Brasil, the federal government's industrial policy, and is projected to create roughly 60 new R&D jobs. The AI platform targets accelerated software development across finance, healthcare, energy, insurance, retail, agriculture and telecom client sectors.

Tanzania's Parliament enacted the Finance Act, No. 11 of 2025 on 30 June 2025 (presidential assent same day), in force 1 July 2025, introducing three structurally distinct amendments to the Mining Act, Cap. 123 that sit on top of the 2024-11-05 Written Laws (Miscellaneous Amendments) (No. 4) Act and the 2025-09-12 Mining (Local Content) (Amendment) Regulations GN 563/2025. (i) New Section 113A creates an "HIV Response Levy" at 0.1% of gross mineral value, payable concurrently with mineral royalty by all mineral-right holders and licensees, allocated 70% to the AIDS Trust Fund (under the Tanzania Commission for AIDS Act, Cap. 379) and 30% to the Universal Health Insurance Fund (under the Universal Health Insurance Act, No. 12 of 2023). (ii) Section 59 of the Mining Act is amended to extend the 20% local-value-addition gold-allocation requirement (mandatory supply of refined gold to domestic smelting, refining, and trading operators) from holders of mineral-development agreements to **all** gold-licence holders with no carve-out. (iii) The withholding-tax rate on non-resident service providers under Section 60 is raised to 10% to incentivise use of local service providers. The amendments combine a new social-fund mineral levy, a horizontal expansion of the domestic-beneficiation mandate, and a tax-side push for service localisation — adding a fiscal-instrument layer on top of the 2024-25 critical-minerals classification and 2025 local-content reservation framework.

On 20 May 2025 the UK Foreign, Commonwealth and Development Office updated the UK Sanctions List, adding 82 entries (20 individuals and 62 entities) under the Russia (Sanctions) (EU Exit) Regulations 2019. OFSI's accompanying Financial Sanctions Notice confirms all 82 are now subject to an asset freeze and trust services sanctions. The package covers three clusters: further members of the Kremlin-linked Social Design Agency (SDA) disinformation network (first designated in 2024); Russian financial institutions including the St Petersburg Currency Exchange, the Petersburg Settlement Center, and the State Corporation Deposit Insurance Agency; and individuals and companies supporting Russia's oil "shadow fleet" logistics, including a British national accused of ship procurement and two tanker captains. The measures were published in coordination with the EU's 17th sanctions package, announced the same day.

Prime Minister Anthony Albanese announced the Critical Minerals Strategic Reserve (CMSR) on 24 April 2025 as a A$1.2bn election commitment in the 2025-26 Budget. The Department of Industry, Science and Resources released the design package on 12 January 2026, prioritising antimony, gallium, and rare earth elements as the initial focus minerals (A$1bn for offtake transactions drawn from an expanded A$5bn Critical Minerals Facility, plus A$185m for physical stockpiling and implementation). The Export Finance and Insurance Corporation Amendment (Strategic Reserve) Act 2026 passed Parliament on 31 March 2026 with effect 1 April 2026, giving Export Finance Australia (EFA) statutory power to enter offtake agreements, contracts for difference, forward contracts, and physical stockpiles for fuel and critical minerals. CMSR becomes operational in second half 2026.

Commission Delegated Regulation (EU) 2025/532, adopted 24 March 2025 and published in the Official Journal on 2 July 2025, supplements DORA (Regulation (EU) 2022/2554) with binding Regulatory Technical Standards governing ICT subcontracting of critical or important functions. It requires all EU-regulated financial entities to establish a subcontracting policy, conduct due-diligence and concentration-risk assessments at each tier of the ICT supply chain (including nth-party providers), impose equivalent resilience standards on sub-ICT-providers, and maintain enforceable termination and information-access rights. The RTS entered into force on 22 July 2025, completing the second-batch DORA implementing acts on outsourcing chains.

HM Treasury's Office of Financial Sanctions Implementation (OFSI), with the UK Foreign Office, announced on 13 January 2025 a sanctions package targeting Russia's oil "shadow fleet" — vessels operated outside Western maritime insurance and flag-state registries to evade the G7+ Russian crude price cap (set at $60/bbl since December 2022). The package designated 18 vessels (oil tankers transporting Russian crude in violation of the cap) and traders, with separate designations of two LNG carriers and two oil-services firms. This is the largest single UK shadow-fleet designation to date and was synchronised with EU Council and US OFAC packages in mid-January 2025.

On January 10, 2025, the US Treasury's Office of Foreign Assets Control (OFAC), acting jointly with the Department of State, designated PJSC Gazprom Neft and PJSC Surgutneftegas as Specially Designated Nationals (SDNs) under Executive Orders 13662 and 14024, alongside more than 180 oil-carrying vessels (the bulk of Russia's "shadow fleet"), dozens of opaque oil traders, two major Russia-based oilfield service providers, marine insurance companies, and senior Russian energy-sector officials. The package included a new EO 14024 sectoral determination authorizing future designations against any person operating in the Russian energy sector, plus a new EO 14071 determination prohibiting the provision of US petroleum services (extraction, drilling, production support) to persons located in the Russian Federation, effective 12:01 a.m. EST on February 27, 2025. OFAC simultaneously issued General Licenses 117 (wind-down of transactions with the newly blocked entities) and 118 (debt/equity/derivatives wind-down), both expiring February 27, 2025. The action was the largest single Russia energy-sector designation since the 2022 invasion regime began and was coordinated with parallel UK OFSI shadow-fleet designations issued the same week. The action was finalized in the closing days of the Biden administration as a deliberate tightening of the oil-revenue and shadow-fleet vectors before the January 20 transition. Subsequent enforcement and any rollback decisions fell to the incoming Trump administration.

FinCEN issued a final rule (89 FR 70258, FR Doc 2024-19198) requiring certain real-estate-closing and settlement professionals to file a new "Real Estate Report" and maintain records on non-financed (i.e., all-cash) transfers of U.S. residential real property to specified legal entities and trusts, on a nationwide basis. The rule uses a "reporting cascade" to designate one filer per transaction (settlement agent, title-insurance underwriter, escrow agent, or attorney, depending on which is present), replacing the long-running geographic-targeting-order (GTO) regime with a permanent nationwide framework. The original effective date of December 1, 2025 was subsequently postponed to March 1, 2026 via a FinCEN exemptive-relief order issued September 30, 2025.

Three Commission Delegated Regulations (CDR 2024/1772, 1773, 1774) adopted 13 March 2024 and published in the EU Official Journal on 25 June 2024 constitute the first batch of binding Level 2 implementing rules under DORA (Regulation (EU) 2022/2554). CDR 2024/1772 sets ICT incident classification criteria and materiality thresholds for mandatory reporting; CDR 2024/1773 specifies the required content of contractual policies for ICT third-party services supporting critical or important functions; CDR 2024/1774 defines the ICT risk management tools, methods, processes, and policies — including a simplified framework for smaller in-scope entities. All three apply from 17 January 2025 alongside the parent DORA regulation, covering approximately 22,000 EU regulated financial entities.

Canada made SOR/2024-32, Regulations Amending the Special Economic Measures (Russia) Regulations, registered and effective 2024-02-21 on the second anniversary of Russia's invasion of Ukraine. The regulations add 163 persons to Schedule 1 — 10 individuals and 153 entities, predominantly Russian organizations tied to military-industrial production, logistics, insurance and oil-sector support — triggering Canadian dealing/asset bans. A parallel amendment to Schedule 7 adds five new goods categories under the Harmonized System (explosives and pyrotechnics; data-processing units and components; ball and roller bearings; semiconductor manufacturing equipment; optical and navigational instruments), banning their export to Russia or Russian persons.

Regulation (EU) 2022/2554 (Digital Operational Resilience Act, DORA) is the EU's first horizontal cyber- and ICT-resilience instrument for the financial sector. Adopted 14 December 2022 and published in the Official Journal on 27 December 2022, it entered into force on 16 January 2023 and applies from 17 January 2025. DORA covers approximately 22,000 EU regulated financial entities across ~20 entity types (credit institutions, insurers, investment firms, CCPs, trading venues, crypto-asset service providers, etc.) under five pillars: ICT risk management, ICT-incident reporting, digital operational resilience testing (including threat-led penetration testing for significant entities), ICT third-party risk management, and information sharing. Structurally novel, DORA establishes the Critical ICT Third-Party Provider (CTPP) oversight regime under which the European Supervisory Authorities (EBA, ESMA, EIOPA) acquire direct supervisory powers over hyperscale cloud providers (AWS, Azure, GCP, Oracle) servicing EU financial entities — the first EU mechanism for ESA direct oversight of non-financial cloud providers.

OFAC issued a determination under Executive Order 14071 (Russian Harmful Foreign Activities Sanctions) effective December 5, 2022, establishing a $60/barrel price cap on Russian seaborne crude oil. The measure prohibits US persons from providing six categories of covered services — trading/commodities brokering, financing, shipping, insurance (including reinsurance and P&I), flagging, and customs brokering — for the maritime transport of Russian crude oil unless the oil is purchased at or below $60/bbl. The determination was coordinated with the EU, G7 nations, and Australia as a unified coalition instrument designed to reduce Russian oil revenues while keeping global energy markets supplied. Three general licenses (GL 55, 56, 57) carved out limited exemptions for Japan's Sakhalin-2 imports, certain EU landlocked states, and vessel emergencies.

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.

On 25 February 2022, the day after Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Regulation (EU) 2022/328, amending Regulation (EU) No 833/2014. It prohibits the sale, supply, transfer or export of dual-use goods and technology to any person, entity or body in Russia, or for military use or military end-users there, and extends to goods and technology suited for use in the oil refining industry and for the aviation and space industry, alongside a ban on related technical assistance, brokering, financing and insurance/maintenance services. The Regulation entered into force on the day after its Official Journal publication (OJ L 49, 25.2.2022), i.e. 26 February 2022.

Qatar's Amir Sheikh Tamim bin Hamad Al Thani promulgated Law No. (1) of 2019 on 7 January 2019, replacing Law No. 13 of 2000 and authorising non-Qatari investors to hold up to 100% equity in Qatari enterprises across all economic sectors, subject to executive regulations. The law provides national-treatment guarantees, protects against expropriation except for public purpose with fair compensation, and permits full repatriation of investment income and capital. Banking, insurance, and commercial agencies remain subject to sector-specific ownership caps unless exempted by the Council of Ministers.

On 9 May 2016 CMOC Group (China Molybdenum Co., HKG:3993 / SHA:603993) signed agreements to acquire Freeport-McMoRan's 56% stake in Tenke Fungurume Mining (TFM) in the Democratic Republic of the Congo for USD 2.65 billion, with additional financing from China Development Bank. A concurrent transaction acquired TF Holdings' 24% stake, bringing CMOC's total to 80% with Gécamines retaining 20%. The transaction closed on 16 November 2016 following regulatory approvals from the DRC Ministry of Mines, the US CFIUS (approved without conditions), and Chinese MOFCOM. Tenke Fungurume is the world's second-largest cobalt mine and fifth-largest copper mine, located in Lualaba Province. At the time of acquisition it produced approximately 16,000 tonnes of cobalt per year (hydroxide) and 180,000 tonnes of copper cathode, representing roughly 20% of global mined cobalt supply. CMOC subsequently expanded production to approximately 50,000 tonnes of cobalt per year by 2023-2024 through the Kisanfu (KFM) discovery development — bringing combined TFM+KFM output to ~115,000 tonnes of cobalt annually, or roughly 38% of DRC cobalt production and approximately 25% of global supply from a single operator. The acquisition was the largest Chinese overseas mining transaction of 2016 and established China's dominant structural position in the cobalt supply chain at the mine level — upstream of both DRC export controls (ARECOMS quota system, filed 2025-02-22) and Chinese processing/re-export controls on battery-grade cobalt compounds. CMOC is simultaneously the world's largest cobalt producer and an entity subject to Chinese government export licensing for the same materials — a concentration structure without precedent in critical minerals. The China Development Bank provided a $2.68 billion loan facility financing the majority of the acquisition, making this an explicit policy-bank-backed strategic asset purchase consistent with NDRC guidelines on overseas critical mineral investment priorities. Sinosure provided political-risk insurance cover on the DRC exposure.

Decreto-Legge 15 marzo 2012 n. 21 (GU n. 63 of 15 March 2012), converted with amendments into Legge 11 maggio 2012 n. 56 (GU n. 111 of 14 May 2012), establishes Italy's "Golden Power" special-powers regime — the foundational statute authorising the Italian Government to impose conditions on, veto, or prescribe remedies for corporate transactions in strategic sectors. The decree marked Italy's transition from a golden-share model (applicable only to privatised companies) to a sector-wide golden-power model applicable to any company carrying out activities of strategic relevance. Administered by the Presidenza del Consiglio dei Ministri (DICA), the regime has been progressively extended from its original defence + national-security + energy/transport/ communications scope to cover 5G, cloud, critical-raw-materials, financial-credit-insurance, agri-food, healthcare, media, space, and AI through a series of amending decrees from 2019 to 2026.