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

Premier Li Qiang signed State Council Order No. 835 on 13 April 2026 promulgating the "Regulations of the People's Republic of China on Countering Foreign States' Unlawful Extraterritorial Jurisdiction" (20 articles), effective on the date of publication. The Regulations are the first State Council–level administrative regulation to operationalise the PRC's framework for identifying and countering foreign extraterritorial measures on a horizontal basis, complementing the 2021 Anti-Foreign Sanctions Law and the March 2025 AFSL implementation regulations. Article 5 establishes a State Council–led inter-agency coordination mechanism; Article 6 vests the State Council legal affairs department (the Ministry of Justice in practice) with authority to identify "improper" foreign extraterritorial measures and to grant exemptions; Article 8 authorises a new Malicious Entity List targeting foreign organisations and individuals that "promote or participate in implementing" such measures, with nine countermeasure categories spanning visa denial, asset freezing, trade restrictions and fines; Article 11 codifies an exemption-application channel under which Chinese persons facing conflicting legal demands may request approval to comply with foreign measures within a defined scope; Article 14 authorises a private right of action for harmed Chinese citizens and organisations to sue parties enforcing such measures; and Article 18 elevates enforcement beyond administrative penalties by referencing potential criminal liability.

On 22 September 2025, OFAC designated Lex Instituto de Estudos Juridicos LTDA (Lex Institute) and Viviane Barci de Moraes — wife of Brazilian Supreme Federal Court (STF) Justice Alexandre de Moraes and the Institute's Managing Partner — pursuant to Executive Order 13818 (the Global Magnitsky Human Rights Accountability Act authority). The Lex Institute is a family holding company that owns de Moraes' residence and other properties; Treasury designated it for materially supporting de Moraes, who was himself designated under the same authority on 30 July 2025 for authorizing arbitrary pre-trial detentions and suppressing freedom of expression, including in the prosecution of former President Jair Bolsonaro. All US property and interests of the designated persons are blocked and U.S. persons are generally barred from transacting with them.

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.

New Zealand's Russia Sanctions Amendment Regulations (No 3) 2025, made under the Russia Sanctions Act 2022, came into force on 19 June 2025 designating seven entities and ten individuals -- including North Korean, Iranian and Belarusian actors supporting Russia's war effort and Russian actors involved in drone and weaponry production. The same instrument created a new "restricted ship" category under Regulation 8 and sanctioned 27 vessels in Russia's shadow fleet under it, and expanded the Regulation 12 legal-services exception. Designated parties are subject to asset freezes and prohibitions on New Zealand persons supplying services to them.

Premier Li Qiang signed State Council Order No. 803 on 23 March 2025 promulgating the "Regulations on Implementation of the Anti-Foreign Sanctions Law of the People's Republic of China" (22 articles), effective on the date of publication (24 March 2025). The Regulations operationalise the 2021 Anti-Foreign Sanctions Law by clarifying the scope of countermeasure tools — explicitly extending "other property" subject to seizure to cash, bank deposits, securities, equity, intellectual property and accounts receivable, and listing the specific transaction and cooperation activities that may be prohibited or restricted (education, S&T, legal services, environment, trade, culture, tourism, health, sports, data and cross-border data transfers). They define inter-agency procedure, evidence and notice requirements for designations, and bind PRC organisations and individuals — including foreign-invested entities operating in China — to implement countermeasures, with sanctions including exclusion from government procurement, import/export and cross-border-data restrictions, and exit/stay restrictions for responsible persons.

OFSI imposed a £465,000 civil monetary penalty on Herbert Smith Freehills CIS LLP (the firm's Moscow subsidiary, "HSF Moscow") for six payments totalling £3,932,392.10 made to three Russia-designated persons — Alfa-Bank JSC, PJSC Sovcombank, and PJSC Sberbank — during the wind-down of the Moscow office in May 2022, in breach of the Russia (Sanctions) (EU Exit) Regulations 2019. The penalty is the first OFSI enforcement action against the legal-services sector and the first against a Big Law firm; OFSI signalled further professional-services enforcement is in the pipeline. HSF London's voluntary disclosure and full cooperation secured a 50% penalty reduction from an initial £930,000 basis.

President Trump signed Executive Order 14203, "Imposing Sanctions on the International Criminal Court," on 6 February 2025, declaring a national emergency under IEEPA over the ICC's "illegitimate and baseless actions targeting America and our close ally Israel." The order authorises OFAC asset-blocking and INA § 212(f) entry suspensions against any foreign person determined by Treasury (in consultation with State) to have directly engaged in or materially assisted ICC efforts to investigate, arrest, detain, or prosecute protected persons (US persons and persons of US-allied non-ICC-state parties such as Israel). On 13 February 2025 OFAC made the first designation under the EO, adding ICC Prosecutor Karim Khan to the SDN List. OFAC subsequently codified the prohibitions into the new 31 CFR Part 528 ("International Criminal Court-Related Sanctions Regulations") published in abbreviated form on 1 July 2025 (FR doc 2025-12036). The program has since been used to designate eight additional ICC judges across 5 June 2025, 20 August 2025, and 18 December 2025 announcements.

The Office of Foreign Assets Control (OFAC) issued a final rule on 19 December 2024 amending 32 parts of 31 CFR chapter V to modernize the general licenses authorizing payments for legal services from funds originating outside the United States. The rule replaces the annual reporting requirement that had applied to such payments with a 10-year recordkeeping requirement, aligning the legal-services general licenses with the new 10-year statute of limitations for IEEPA/TWEA violations and OFAC's parallel 5→10-year recordkeeping extension (31 CFR 501). The rule also standardises legal-services general-license language across programs — removing legacy letter-of-engagement prerequisites in certain parts (e.g., 31 CFR 594, 597), updating 31 CFR 549 (Lebanon) and 31 CFR 576 (Iraq Stabilization and Insurgency) to remove the requirement that payments for authorised legal services be separately specifically licensed, and harmonising the 31 CFR 591 (Venezuela-related) authorisation language. The rule was effective 19 December 2024 with an applicability date of 12 March 2025.

OFAC amended and reissued the Global Magnitsky Sanctions Regulations (31 CFR Part 583) in their entirety on 12 March 2024, to implement the Global Magnitsky Human Rights Accountability Act and EO 13818 (20 December 2017) more fully. The reissuance adds expanded interpretive guidance, new definitions (agricultural commodities, medicines, medical devices), new statutory authority (Uyghur Human Rights Policy Act of 2020), and several new general licenses covering blocked-account management, legal services, personal-use medical/food transactions, and emergency services. No new SDN designations or country-level targeting; the action is a compliance-architecture update that clarifies permissible conduct and tightens procedural standards across the global human-rights-and-corruption sanctions program.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) published a final rule in the Federal Register (89 FR 15769, FR Doc 2024-04500) renaming the Darfur Sanctions Regulations (31 CFR Part 546) to the Sudan Stabilization Sanctions Regulations and amending them to implement Executive Order 14098 of May 4, 2023. E.O. 14098 broadened US sanctions authority beyond the Darfur-specific frame to cover all persons destabilising Sudan and undermining democratic transition, responding to the SAF–RSF armed conflict that erupted in April 2023. The rule adds new general licenses covering legal-service payments (§ 546.508), African Union transactions (§ 546.511), and agricultural/medical exports (§ 546.513), and introduces an interpretative provision clarifying that entities are not automatically blocked solely because a blocked individual holds a leadership position.

OFAC amended the Weapons of Mass Destruction Proliferators Sanctions Regulations (31 CFR Part 544), implementing Executive Order 13382 (28 June 2005, blocking property of WMD proliferators and their supporters). The rule revised existing General License Section 544.507 by removing the requirement that all payment receipts for legal services must be specifically licensed, and added a new General License Section 544.508 authorising payments for legal services from funds originating outside the United States under defined conditions. The amendment aligns Part 544's legal-services framework with the broader cross-program approach OFAC was standardising across sanctions programmes during this period.

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) published the International Criminal Court-Related Sanctions Regulations as an interim final rule effective 1 October 2020, codifying into 31 CFR Part 520 the IEEPA-based asset-blocking authorities delegated by President Trump's Executive Order 13928 of 11 June 2020. The regulations authorised OFAC to block the property and property interests of persons determined to have materially assisted, sponsored, or supported ICC efforts to investigate, arrest, detain, or prosecute any U.S. or allied-nation personnel without consent. No individual designations were made under 31 CFR Part 520 before the programme was terminated by President Biden's EO 14022 in April 2021 and OFAC struck the part from the CFR effective 6 July 2021.