Industrial Policy & Trade Monitor· 2675 actions· ✨ 91 recent

U.S. Customs and Border Protection published a final notice in Customs Bulletin and Decisions, Vol. 59, No. 49 (31 December 2025), revoking two New York ruling letters (NY N019900, dated 2007, and NY N159975, dated 2011) that had classified certain submersible remotely operated vehicles (ROVs) — used in offshore oil and gas, military, and underwater construction operations — under HTSUS heading 8906.90.0090 ("other vessels"), which is duty-free. Per Headquarters Ruling Letter H272339, CBP determined the ROVs lack the essential characteristics of "vessels" (they do not float, have tether-limited navigability, and are not designed to transport persons or goods) and reclassifies them under subheading 8479.89.95 ("other machines and mechanical appliances having individual functions"), which carries a 2.5% general (MFN) duty rate. No comments were received on the September 2025 proposed notice. The change takes effect 60 days after publication, i.e. 1 March 2026, and also revokes/modifies any other unidentified ruling covering the same merchandise.

On 26 December 2025 the President of Kazakhstan signed a law amending the Code "On Subsoil and Subsoil Use" with respect to the hydrocarbon and uranium sectors, followed on 30 December 2025 by a parallel set of amendments implementing presidential instructions on broader subsoil-use governance. Both packages take effect on 2 March 2026. The uranium amendments grant the National Atomic Company Kazatomprom (KAP) a statutory priority right to obtain exploration licences over prospective uranium areas listed in the State Subsoil Fund Management Programme, and to reserve blocks containing uranium mineralisation or deposits. Where uranium mineralisation is discovered on a solid-mineral block held by a third-party subsoil-user, an extension of that licence is conditional on the licensee surrendering the uranium-bearing block to the State; private subsoil-users no longer obtain priority production rights for uranium they discover. The amendments also raise the minimum direct or indirect Kazatomprom interest in any uranium mining project from 50% to 75%, and permit subsequent transfer to investors or joint-venture partners only subject to that 75% floor. The 30 December 2025 package establishes the National Geological Service as a non-privatisable national operator subordinate to the authorised subsoil-exploration agency and as the operator responsible for managing geological information; it also creates a Unified Subsoil Use Platform digital infrastructure (open geological-information database integrated with the Unified State System for Management of the Fuel and Energy Complex). The hydrocarbon track of the law shortens block-reservation periods and pushes unallocated plots into electronic-auction allocation to accelerate competitive exploration. The amendments accompany an announced USD 500m state geological-exploration programme.

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.

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.

Emissions Reduction Alberta (ERA), a provincial Crown corporation funded through Alberta's Technology Innovation and Emissions Reduction (TIER) carbon-levy system, launched a CAD 22.4 million (approx. USD 16 million) Methane Reduction Deployment Program on 2025-11-12. The program funds up to 50% of eligible project costs, capped at CAD 1 million per project, for owners and operators of upstream and midstream oil and gas facilities in Alberta to deploy commercial-ready methane detection, measurement and reduction technologies. Global Trade Alert logs the program as a trade-distorting financial grant given its effect on the relative cost competitiveness of Alberta oil and gas production versus other producing jurisdictions.

Japan Bank for International Cooperation (JBIC), Japan's state export-credit and outbound-investment finance institution, signed a credit line agreement on 2025-11-12 providing USD 360 million of a USD 600 million total facility to Petróleo Brasileiro S.A. (Petrobras), Brazil's state-controlled oil company. The credit line, extended under JBIC's GREEN Operations framework, is earmarked to fund decarbonization, energy-transition, and environmental projects implemented by Petrobras or its subsidiaries in Brazil, including alignment with the Initiative for Sustainable Fuel and Mobility (ISFM), a Japan-Brazil biofuels/mobility-technology programme, and Brazil's 2050 net-zero target. The agreement was signed during COP30 in Belém, Brazil.

Brazil's national development bank BNDES signed a BRL 2.5 billion (~USD 471.6 million) financing contract with Starnav Serviços Marítimos on 22 September 2025 in Itajaí (Santa Catarina), drawing on the Merchant Marine Fund (Fundo da Marinha Mercante, FMM). The loan covers just over 88% of the ~BRL 2.9 billion cost of eight hybrid (diesel-electric with battery banks) multipurpose offshore support vessels — four Platform Supply Vessels (PSV) and four Oil Spill Recovery Vessels (OSRV), each 5,500 dwt — to be built at the Detroit Brasil shipyard in Itajaí. The vessels will be chartered to state oil company Petrobras under 12-year contracts to support offshore oil and gas production, and the project is projected to generate 1,400 direct and 6,300 indirect jobs. The announcement was part of a wider BRL 3.3 billion BNDES package for Santa Catarina covering naval, highway and agroindustry financing.

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 2 September 2025 Mexico's Finance Ministry (SHCP) launched a capitalisation and refinancing strategy for state oil company Petróleos Mexicanos (Pemex), opening a USD 12 billion bond repurchase offer (of which USD 9.9 billion targeted 2026-2029 maturities). Between 15-16 September, SHCP placed a new basket of euro- and dollar-denominated bonds totalling USD 13.8 billion equivalent (EUR 5 billion across 4/8/12-year tranches at 3.500%, 4.500% and 5.125% coupons; USD 8 billion across 5/7/10-year tranches at 4.750%, 5.375% and 5.625% coupons), taking the combined operation to roughly USD 21.8 billion. SHCP stated the goal was to strengthen Pemex's capitalisation levels, reduce its financial debt balance, manage supplier obligations, fund investment projects, and improve its debt-maturity profile. The operation is part of the government's 2025-2035 Pemex strategic (rescue) plan and preceded credit-rating upgrades from Fitch (B+ to BB) and Moody's (B3 to B1, stable outlook).

Brazil's national development bank BNDES approved a BRL 186.1 million (~USD 33.6 million) financing operation for Bram Offshore Transportes Marítimos Ltda, part of the US Edison Chouest Offshore group and the largest offshore-support vessel operator in Brazil. The loan, drawn from the Merchant Marine Fund (Fundo da Marinha Mercante, FMM), covers 90% of a BRL 206.8 million project to repair, modernise and convert 15 support vessels — including hybrid-propulsion retrofits (battery installation) on at least one Petrobras-chartered vessel — at the Navship shipyard in Navegantes, Santa Catarina. The same BNDES announcement included a separate BRL 53.2 million FMM loan to Estaleiro Navship Ltda to resume pandemic-halted shipyard works at Porto do Açu (São João da Barra, RJ).

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 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.

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.

Emissions Reduction Alberta (ERA), a provincial Crown corporation funded through Alberta's Technology Innovation and Emissions Reduction (TIER) carbon-levy system, launched the Tailings Technology Challenge on 2025-06-17 with up to CAD 50 million in funding. The program covers up to 50% of eligible project costs, with individual project awards ranging from CAD 1 million to CAD 15 million, for pilot, demonstration and first-of-kind commercial projects that treat, reduce, reuse or reclaim oil sands mine water and tailings. Global Trade Alert logs the program as a trade-distorting financial grant given its effect on the relative cost competitiveness of Alberta oil sands operators versus other producing jurisdictions.

Bank Pembangunan Malaysia Berhad (BPMB) and Export-Import Bank of Malaysia Berhad (EXIM Bank), both wholly state-owned development finance institutions under the BPMB Group, jointly announced on 2025-05-26 a RM700 million (approximately USD 166 million) financing package for Duta Marine Sdn Bhd, a Bumiputera-owned offshore marine services company. The facility comprises RM555 million from BPMB and USD 37 million in Islamic financing from EXIM Bank, funding the acquisition, conversion, refurbishment and mobilisation of an oil tanker into a floating storage and offloading (FSO) vessel — FSO Permata Dulang — to replace the ageing FSO Puteri Dulang serving Malaysia's Dulang oil field under a 10+5 year charter with Petronas Carigali.

On 8 May 2025 the Verkhovna Rada ratified the 30 April 2025 Washington intergovernmental agreement establishing the U.S.-Ukraine Reconstruction Investment Fund (draft law 0309, 338 of 450 MPs in favour); President Zelenskyy signed the ratification law on 12 May 2025. On 4 June 2025 the Rada then adopted in second reading and as a whole the implementing amendments to the Budget Code of Ukraine (draft law 13256, 309 MPs in favour), which credit half of royalties from new licences for the extraction of minerals of national importance (per Annex A of Cabinet Resolution 845) and half of state share revenues under new production-sharing agreements to a State Budget special fund earmarked for transfer to the joint Fund. The Fund is jointly managed 50/50 by the US International Development Finance Corporation (DFC) and a Ukrainian state entity, gives the US first-look preferential access to new lithium, titanium, REE, graphite, uranium and oil-and-gas projects, and is the structural anchor of the 2025 US critical-minerals pivot away from China.

On 11 April 2025 President Javier Milei signed Decreto de Necesidad y Urgencia 269/2025, published in the Boletín Oficial on 14 April 2025 (edición Nº 35.647). The decree repealed Decreto 28/2023, formally lifting the cepo cambiario — the foreign-exchange restrictions that had been in continuous operation in some form since November 2011. Operative provisions include elimination of the 80/20 export-proceeds-channelling mandate, removal of individual USD purchase and wire-transfer caps, permission for companies to repatriate post-1-January-2025 dividend profits, and replacement of the daily crawling-peg with a band float within a $1,000–$1,400 ARS/USD corridor with BCRA floor/ceiling intervention rules. The measure was coordinated with the IMF Extended Fund Facility (USD 20bn total; USD 15bn 2025 free-availability tranche) approved 11 April 2025, and operationalises the currency-stability guarantee embedded in the RIGI large- investment regime (Law 27.742, July 2024).

The Nigeria Data Protection Commission issued the General Application and Implementation Directive (GAID) 2025 on 20 March 2025, the principal implementing directive of the Nigeria Data Protection Act 2023 (NDPA). The GAID came fully into force on 19 September 2025, replacing the Nigeria Data Protection Regulation (NDPR) 2019 as the operative enforcement instrument. It applies extraterritorially to any data controller or processor established outside Nigeria that processes personal data of Nigerian data subjects, imposes a tripartite cross-border transfer framework (adequacy decisions, Transfer Instruments, and statutory exceptions), mandates Data Protection Impact Assessments for AI and high-risk technologies, and carries a civil-penalty ceiling of 2% of annual gross revenue or NGN 10 million for designated data controllers and processors of major importance (DCPMIs), whichever is greater.

Papua New Guinea's Parliament passed the Income Tax Act 2025 (Act No. 11 of 2025) on 20 March 2025, replacing the Income Tax Act 1959 in its entirety and taking effect from 1 January 2026. The Act introduces PNG's first-ever capital gains tax (CGT) at a flat 15% rate on gains from the direct or indirect disposal of interests in extractive assets (mining tenements, petroleum licences, and associated infrastructure). An offshore indirect transfer rule closes the longstanding "Double Dutch" structure used to transfer PNG mineral licences via overseas holding-company share sales without PNG tax exposure: any transaction resulting in a 10%-or-greater change in beneficial ownership of a PNG extractive licensee triggers a notification obligation and deemed disposal, crystallising CGT liability for the offshore transferor. No sector carve-out exists; KPMG and PwC analyses confirm CGT applies uniformly to all mining, oil, and gas disposals.

Papua New Guinea's National Parliament passed the National Petroleum Authority Act 2025 on 12 March 2025 (vote 84–0), establishing the National Petroleum Authority (NPA) as a new statutory regulator replacing the Department of Petroleum and Energy. The companion Oil and Gas (Amendment) Act 2025 was passed the same week, realigning the Oil and Gas Act 1998 licensing framework with NPA oversight. Both Acts commenced on 9 April 2025 via Notice in the National Gazette. A new 0.5% gross-revenue levy on crude oil, natural gas, LNG, condensates, and LPG applies to all Petroleum Production Licence holders, directly affecting ExxonMobil's PNG LNG (8.3 Mtpa), TotalEnergies' Papua LNG (4 Mtpa, FID expected 2026–27), and Santos' legacy Oil Search holdings.

Indonesia issued Government Regulation (Peraturan Pemerintah) No. 8 of 2025 on Foreign-Exchange Proceeds from Natural-Resource Exports (DHE SDA), amending PP No. 36/2023. President Prabowo Subianto announced the policy at Merdeka Palace on 17–18 February 2025 and the regulation takes effect on 1 March 2025. It mandates that exporters of non-oil- and-gas mining, plantation, forestry, and fisheries products with export-proceeds value of USD 250,000 or more per shipment retain 100 percent of those foreign-exchange proceeds inside Indonesia's financial system for 12 months — sharply up from the prior 30 percent for 3 months under PP 36/2023. Oil-and-gas exporters remain on the earlier 30 percent / 3-month regime. Permitted in-period uses include rupiah conversion at the holding bank, payment of state obligations in foreign currency, dividend distribution, payment for imported raw materials and capital goods unavailable domestically, and servicing of foreign-currency capital-expenditure loans. Non-compliance carries administrative sanctions including suspension of export services. The government has projected the measure could lift retained foreign- exchange proceeds by USD 80 billion in 2025 and over USD 100 billion on a full 12-month basis.

President Trump signed three Executive Orders on 1 February 2025 (EO 14193, 14194, 14195) declaring national emergencies under IEEPA over the cross-border flow of fentanyl + illegal migration, and using that authority to impose new tariffs: 25% on imports from Canada (with a reduced 10% rate on Canadian energy products), 25% on imports from Mexico, and an additional 10% on imports from China (separate from pre-existing Section 301 + Section 232 tariffs). The tariffs took effect 4 February 2025. On 3 February 2025 the administration announced a 30-day pause for both Canada and Mexico following bilateral border-enforcement commitments; the China tariff was not paused. China responded 4 February with retaliatory tariffs of 15% on US LNG/coal/farm equipment and additional measures. The package set the precedent for the broader 2 April 2025 "Liberation Day" reciprocal-tariff regime (filed: 2025-04-02-us-trump-reciprocal-tariff-regime).

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.