Industrial Policy & Trade Monitor· 2670 actions· ✨ 89 recent

Ukraine's President Volodymyr Zelenskyy signed Decree No. 8/2026 on 3 January 2026, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 95 individuals and 70 legal entities, the large majority of them Russian citizens, residents, and companies. The designees manufacture or supply communications equipment, radio-electronic warfare (REB) systems, and microelectronics for Russia's defense-industrial complex, alongside chemical, mining, metallurgical, and fuel-and-energy-sector entities and their managers. The decree entered into force on 6 January 2026, the date of official publication.

Ukraine's President signed Decree No. 870/2025 on 29 November 2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 26 Russian legal entities involved in crude petroleum and natural gas extraction, petroleum-product refining, and related energy-sector activity. The decree imposes asset freezes and bars commercial transactions and investment dealings with the designated entities. It entered into force on 2 December 2025, the date of official publication.

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 July 2025, the US Treasury's Office of Foreign Assets Control designated a network of UAE- and UK-based companies controlled by Iraqi-British businessman Salim Ahmed Said that has smuggled Iranian oil disguised as Iraqi crude since at least 2020, plus five additional shadow-fleet vessel owners based in Seychelles, the Marshall Islands, and the British Virgin Islands. The action, taken pursuant to E.O. 13902 (Iran petroleum sector) and E.O. 13224 (counterterrorism), also identifies several tankers as blocked property and marks the eighth round of sanctions under National Security Presidential Memorandum 2's Iran maximum-pressure campaign. Concurrently, the State Department designated six additional entities and four vessels under E.O. 13846.

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.

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register "Directive 1 under Executive Order 14014, 'Prohibitions Related to Financial Services to or for the Benefit of Myanma Oil and Gas Enterprise.'" The Directive — originally issued on OFAC's website on 2023-10-31 with a 2023-12-15 effective date — determines that MOGE is a political subdivision, agency, or instrumentality of the Government of Burma and prohibits U.S. persons from providing, exporting, or reexporting, directly or indirectly, financial services to or for the benefit of MOGE. The Federal Register publication codifies notice of the Directive in the formal record of agency action; the underlying prohibition has been operative since December 2023.

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.

Switzerland's Federal Council amended the Ordinance on measures in connection with the situation in Ukraine (SR 946.231.176.72) to align with the EU's eighth sanctions package, effective 6pm on 23 November 2022. The amendment creates the Swiss legal basis for an oil price-cap mechanism — banning maritime transport to third countries of Russian-origin crude oil and petroleum products unless purchased at or below a price cap to be set later (the G7/EU $60/bbl cap followed on 3 December 2022; see the companion US OFAC determination of 2022-12-05). It also extends import/export restrictions to additional iron and steel products and aerospace goods, bans the provision of IT, engineering, architecture and legal services to the Russian government and Russian companies, bans Swiss nationals from holding board seats at certain Russian state-owned companies, fully bans crypto-asset wallet/account/custody services to Russian persons regardless of value, and adopts an arms embargo against Russia (extended in part to Ukraine for reasons of Swiss neutrality).

On 6 October 2022 the Council of the European Union adopted Council Regulation (EU) 2022/1904, amending Regulation (EU) No 833/2014, as the EU's eighth package of restrictive measures against Russia. It entered into force 7 October 2022. The regulation's headline measure creates the legal basis for an oil price-cap mechanism: a ban on maritime transport to third countries of Russian-origin crude oil and petroleum products, becoming operational once the Council sets an actual cap level by a separate decision (the G7/EU $60/bbl cap followed on 3 December 2022). The package also expands import bans on steel products (phased through 2024), firearms and ammunition, wood pulp and paper, and certain chemicals, cosmetics and jewellery materials; extends export bans on aviation-sector goods; bans the provision of architectural, engineering, IT-consultancy and legal advisory services to the Russian government and Russian companies; and imposes restrictions on Russian-flagged vessels at the Russian Maritime Register.