Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

On 1 June 2026, the U.S. Treasury's Office of Foreign Assets Control (OFAC) announced that FTI Consulting, Inc. (NYSE: FCN), a global business-advisory and expert-witness firm, agreed to pay $1,050,000 to settle apparent civil liability for six indirect dealings in prohibited debt of VTB Bank OAO between April 2019 and May 2021 — constituting violations of the Russia Harmful Foreign Activities Sanctions Regulations (RuHSR) and the then-applicable Directive 1 debt-tenor restrictions. FTI had been engaged via an intermediary global law firm to provide expert economic consulting services supporting VTB in Singapore litigation; invoices issued through that intermediary went unpaid or were paid far beyond the permissible 14-day tenor, extending prohibited debt on six occasions totalling approximately $353,862. OFAC determined the conduct was non-egregious and not voluntarily self-disclosed, and imposed a penalty of $1,050,000 — double the $525,000 base penalty — citing the foundational principle that a party may not do indirectly what it cannot do directly.

OFAC reached a $1,720,000 civil penalty settlement with IMG Academy LLC on 12 February 2026 to resolve 89 apparent violations of the Foreign Narcotics Kingpin Sanctions Regulations (31 CFR Part 598) arising from tuition-related transactions processed on behalf of two individuals designated as SDNs under the Kingpin Act between 2018 and 2023. OFAC determined the apparent violations were NON-EGREGIOUS and not voluntarily self-disclosed; the penalty reflects substantial cooperation and remedial measures taken by IMG Academy after becoming aware of the violations. This is the first OFAC enforcement action in the register against a US educational or academic-services institution, establishing Kingpin Act SDN-screening obligations for schools and training academies accepting international student tuition payments.

On 29 January 2026, the Council of the European Union adopted Council Implementing Regulation (EU) 2026/267 and the accompanying Council Decision, implementing the EU's Iran human-rights restrictive-measures regime (Regulation (EU) No 359/2011, in place since 2011 and renewed annually). The package designates 15 individuals and 6 entities over the violent repression of peaceful protests, arbitrary detention, and internet/media censorship in Iran, bringing the regime's cumulative total to 24 individuals and 26 entities. The six newly listed entities are the Iranian Audio-Visual Media Regulatory Authority (SATRA), the IRGC-linked Seraj Cyberspace Organization, the Working Group for Determining Instances of Criminal Content (WGDICC), Yaftar Pazhohan Pishtaz Rayanesh Limited Company, Douran Software Technologies, and Masaf Institute. Designated parties are subject to an EU-wide asset freeze and a prohibition on making funds or economic resources available to them; listed individuals additionally face a travel ban.

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

The UK government designated Russian media entity Rybar LLC and its director-general Mikhail Zvinchuk, alongside Aleksandr Dugin, the Foundation for the Support and Protection of the Rights of Compatriots Living Abroad (Pravfond), and affiliated entities Euromore, Golos, and the Center for Geopolitical Expertise, under the Russia (Sanctions) (EU Exit) Regulations 2019. The designations impose asset freezes and bans on commercial transactions and investment instruments with the named parties, on the basis that Rybar runs a foreign information manipulation and interference (FIMI) network promoting Russian state interests and destabilising Ukraine. Pravfond's network was separately alleged to have moved funds across at least 11 EU member states to fund pro-Kremlin media outlets while concealing state ties.

The U.S. Treasury's Office of Foreign Assets Control designated four individuals and four entities under Executive Order 14098 ("Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition") for operating a transnational network that recruits former Colombian military personnel to fight for Sudan's Rapid Support Forces (RSF) paramilitary. Designated persons include retired Colombian officer Alvaro Andres Quijano Becerra, his wife Claudia Viviana Oliveros Forero, the Colombia-based recruitment agency International Services Agency (A4SI), and Panama-based intermediary Talent Bridge, S.A. (formerly Global Staffing S.A.). All property and interests in property of the designated persons subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from transacting with them.

On 19 November 2025, the U.S. Treasury's Office of Foreign Assets Control (OFAC), in a coordinated action with Australia's Department of Foreign Affairs and Trade and the UK's Foreign, Commonwealth and Development Office, designated 5 individuals and 7 companies linked to two Russia-based "bulletproof hosting" (BPH) providers, Media Land and Aeza Group, under Executive Order 13694. Media Land and its subsidiaries (Media Land Technology, Data Center Kirishi, ML Cloud) supplied server infrastructure to ransomware groups including LockBit, BlackSuit and Play. The designations also targeted three companies Aeza Group used to evade its July 2025 OFAC designation and rebrand its infrastructure: Hypercore Ltd. (United Kingdom), Smart Digital Ideas DOO (Serbia), and Datavice MCHJ (Uzbekistan). All designated persons' U.S.-nexus assets are blocked and U.S. persons are prohibited from transacting with them.

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

On 3 September 2025, OFAC announced a civil penalty settlement with Fracht FWO Inc. — a Houston, Texas-based freight forwarder and US subsidiary of Switzerland-headquartered Fracht AG — under which the company agreed to pay USD 1,610,775 to settle its potential civil liability for apparent violations of multiple OFAC sanctions programs. The violations arose from Fracht FWO's brokering of cargo shipments involving EMTRASUR, a wholly owned subsidiary of OFAC-designated Venezuelan state airline CONVIASA, on a Mexico-to-Argentina route on which Iranian crew members were subsequently discovered. Fracht self-initiated a voluntary disclosure to OFAC after learning of the Iranian crew involvement, triggering mitigating credit, and undertook extensive remedial compliance measures. The settlement resolves apparent violations of the Venezuela Sanctions Regulations (VSR), Weapons of Mass Destruction Proliferators Sanctions Regulations (WMDPSR), Global Terrorism Sanctions Regulations (GTSR), and Iranian Transactions and Sanctions Regulations (ITSR).

On 16 August 2025, Ukraine's President signed Decree No. 599/2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 39 individuals and 55 legal entities identified as involved in developing, manufacturing, or supplying components for Russian unmanned aerial vehicles (UAVs) with artificial-intelligence elements. The list covers 43 Russian entities (including drone makers Prognatik, Rozumni Ptakhy, Zala Aero, and KB Vostok, plus AI research centres Neurolab and TsBST), 10 Chinese suppliers of navigation receivers, engines, cameras, and microchips (including Dongguan Standard Trading, Zhejiang Lianxing Machinery, Shenzhen Sky Bow Navigation Technology, and Topscom Precision Industry), and 2 Belarusian component suppliers. Sanctions impose asset freezes and restrictions on commercial transactions and investment instruments, entered into force immediately upon signature and revocable no later than 15 August 2035.

The US Treasury's Office of Foreign Assets Control designated five entities and one individual based in Iran, Hong Kong, Taiwan and China for procuring CNC (computer numerical control) machine tools on behalf of Iran Aircraft Manufacturing Industrial Company (HESA), the state-owned defense-ministry subsidiary that builds Iran's Ababil-series military UAVs used by the IRGC. Designated parties include Javad Alizadeh Hoshyar, CEO of Iran-based Control Afzar Tabriz Co Ltd, which used Hong Kong-based Clifton Trading Limited as an intermediary to obscure CNC-machine shipments to HESA, and Taiwan-based Mecatron Machinery Co Ltd and Joemars Machinery and Electric Industrial Co Ltd, which shipped CNC machines toward Iran through similar concealment channels. The action was taken pursuant to National Security Presidential Memorandum 2 (NSPM-2), which directs that Iran be denied conventional and asymmetric weapons capabilities. All designated parties' US property and interests are blocked and US persons are generally barred from transacting with them.

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.

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

Canada made SOR/2025-142, Regulations Amending the Special Economic Measures (Russia) Regulations, registered 2025-06-13. The regulations add 34 Russian entities to Part 2 of Schedule 1 alongside Keremet Bank Open Joint-Stock Company (Kyrgyzstan), three UAE-based entities, one Singapore-based entity, and two energy-commodity trading companies (Switzerland, Azerbaijan) — all designated as sanctions-evasion intermediaries for Russian trade. The amendments also add 201 vessels (by IMO number) to Schedule 1.1 as part of Russia's "shadow fleet," triggering a dealings ban, asset freeze, and a new prohibition on providing financial or other services to non-Canadians in relation to a listed vessel.

On 20 May 2025, the Council of the European Union adopted Council Implementing Regulation (EU) 2025/965 and Council Decision (CFSP) 2025/966, implementing the EU's dedicated hybrid-threats restrictive- measures regime (Regulation (EU) 2024/2642) rather than the sectoral Russia sanctions track. The package designates 21 individuals and 6 entities for enabling Russian state-sponsored destabilising activity, including information manipulation and interference and cyberattacks against the EU and its partners. Named entities include Stark Industries Solutions Ltd (UK-registered "bulletproof" web-hosting provider used as infrastructure for Russian cyberattacks) and its owner/CEO Ivan and Iurie Neculiti, Czech-based pro-Kremlin media outlet Voice of Europe, and Turkish media company AFA Medya and its founder Hüseyin Doğru. Designated parties are subject to an EU-wide asset freeze and prohibition on making funds available; designated individuals additionally face a travel ban. This is a distinct legal instrument from the same-day 17th Russia sectoral sanctions package (Regulation (EU) 2025/932/933), adopted under the separate hybrid- threats horizontal regime.

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.

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.

India's Directorate General of Foreign Trade issued Notification No. 06/2025-26 on 2 May 2025, inserting new Para 2.20A into the Foreign Trade Policy 2023: direct or indirect import or transit of all goods originating in or exported from Pakistan is prohibited with immediate effect, until further orders, regardless of whether the goods are otherwise freely importable. The government cited national security and public policy grounds; any exception requires prior Government of India approval. The Central Board of Indirect Taxes and Customs followed on 3 May 2025 with Instruction No. 07/2025-Customs directing field formations to enforce the ban. The measure followed the 22 April 2025 Pahalgam terror attack and preceded a brief India-Pakistan military exchange in early May 2025.

On 4 February 2025, President Donald J. Trump signed National Security Presidential Memorandum/NSPM-2, "Imposing Maximum Pressure on the Government of the Islamic Republic of Iran, Denying Iran All Paths to a Nuclear Weapon, and Countering Iran's Malign Influence." The memorandum reimposes the first- term "maximum pressure" framework, directing the Secretaries of State and Treasury and the Attorney General to (i) drive Iran's exports of crude oil and petroleum products — including to the People's Republic of China — to zero; (ii) review and modify or rescind sanctions waivers and general licences (notably the Chabahar port waiver benefiting India); (iii) sanction shadow-fleet vessels, intermediaries, refineries (including PRC "teapot" refiners) and oil traders facilitating Iranian energy exports; and (iv) lead a diplomatic isolation campaign including a snapback of UN Security Council sanctions under JCPOA Resolution 2231 paragraph 11. Since promulgation, OFAC has designated 1,000+ Iran-related persons, vessels and aircraft and four PRC independent ("teapot") refiners alleged to have processed sanctioned Iranian crude. The DOJ is also directed to pursue impoundment of Iranian oil cargoes and seizure of Iranian assets to satisfy US-court terrorism-victim judgments.

President Biden signed into law on 13 May 2024 the Prohibiting Russian Uranium Imports Act (Division H of the National Security Supplemental Appropriations Act, Public Law 118-50). The law bans imports to the United States of unirradiated low-enriched uranium (LEU) produced in Russia or by Russian state entities, effective immediately, with a waiver mechanism allowing the Department of Energy to grant case-by-case exceptions through 2027 where no alternative supply is available. The law also authorised up to $2.72B to support US uranium enrichment capacity via CENTRUS and allied enrichment partnerships.

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

On 3 June 2022 the Council of the European Union adopted Regulation (EU) 2022/879, the sixth package of sanctions against Russia over the invasion of Ukraine, further amending Regulation (EU) No 833/2014. It bans the seaborne import of Russian crude oil and refined petroleum products, covering roughly two-thirds of EU oil imports from Russia at adoption (pipeline deliveries via Druzhba were temporarily exempted). It removes Sberbank, Credit Bank of Moscow and Russian Agricultural Bank from SWIFT (Annex XIV), bans EU operators from providing accounting, auditing, bookkeeping, tax consulting, business/management consulting and public-relations services to persons in Russia (new Article 5n), and adds three more Russian broadcasters to the EU broadcasting-suspension list (Annex XV). It entered into force on 4 June 2022, the day after publication in the Official Journal.

On 1 March 2022, OFAC published an interim final rule adding the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR) at 31 CFR Part 587, codifying into Title 31 of the Code of Federal Regulations all prohibitions previously imposed by Executive Order 14024 of 15 April 2021. The regulations were issued in abbreviated form to provide immediate public guidance, with OFAC indicating an intent to supplement them with additional definitions, general licenses, and interpretive guidance. All transactions prohibited under EO 14024 — including prior sectoral determinations and directives targeting Russia's financial services sector, sovereign debt markets, and key state institutions — are formally prohibited under Part 587, giving domestic courts and compliance teams a stable regulatory anchor.

The US Department of the Treasury's Office of Foreign Assets Control (OFAC) published abbreviated Hong Kong-Related Sanctions Regulations at 31 CFR Part 585, codifying the sanctions framework established by Executive Order 13936 of July 14, 2020 ("The President's Executive Order on Hong Kong Normalization"). The regulations prohibit all transactions with persons designated under EO 13936 — those determined to have undermined Hong Kong's autonomy or contributed to the erosion of freedoms guaranteed under the Sino-British Joint Declaration — and add designated persons to the OFAC Specially Designated Nationals (SDN) list. OFAC published the rules in abbreviated form for immediate public guidance, with intent to supplement with full interpretive guidance, general licenses, and licensing policy.