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On June 21, 2026, OFAC issued Iran-related General License X (GL X), authorizing transactions otherwise prohibited under the Iranian Transactions and Sanctions Regulations (31 CFR part 560), the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587), the Ukraine-/Russia-Related Sanctions Regulations (31 CFR part 589), and WMD-proliferation sanctions authorities — including new purchases and loadings of Iranian-origin crude oil, petrochemical, and petroleum products, a materially broader carve-out than the cargo-already-loaded window granted by the preceding General License U. Just 16 days later, on July 7, 2026, OFAC issued General License X1, revoking and superseding GL X: as of that date new purchases or loadings of Iranian-origin crude oil, petrochemical, or petroleum products were no longer authorized. GL X1 itself subsequently expired. OFAC formally published both web licenses in the Federal Register on September 30, 2026 — a retrospective publication of licenses already issued and, by then, already revoked and expired.

On 9 May 2026 Mozambique's Assembleia da República approved, by consensus of all four parliamentary caucuses under an urgency procedure submitted by President Daniel Chapo, a standalone Lei de Conteúdo Local establishing the legislative-level local-content framework for the country's petroleum and natural gas megaprojects. The law was promulgated on 5 June 2026. It defines goods and services as qualifying local content when they meet at least one of three thresholds: ≥80% national production factors, ≥40% Mozambican company ownership, or a predominantly Mozambican payroll. It mandates integration of national labour, preference for Mozambican subcontractors and goods-and-services suppliers, and creates a dedicated Local Content Agency (Agência de Conteúdo Local) to oversee compliance and enforce penalties. Primary application: TotalEnergies Area 1 (Mozambique LNG) and ExxonMobil/Eni Area 4 (Rovuma LNG / Coral South).

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.

President Trump signed Executive Order 14404, "Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy," on 1 May 2026. The order operationalises the country-specific national emergency declared by EO 14380 (29 January 2026) — which had been preserved after the SCOTUS *Learning Resources* vacatur of the IEEPA tariff authority — by establishing a sectoral OFAC blocking regime. Section 2 authorises asset-blocking against any foreign person determined by the Secretary of Treasury (in consultation with State) to operate in Cuba's energy, defense and related materiel, metals and mining, financial services, or security sectors, or "any other sector" subsequently designated. Section 3 suspends entry under INA § 212(f) for covered aliens. Section 4 authorises secondary sanctions against foreign financial institutions that knowingly conduct or facilitate significant transactions for blocked persons, with both correspondent-account and SDN-listing remedies. The EO itself includes no annex of named designations — those are issued by OFAC under separate determinations.

On May 1, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated China-based independent ("teapot") refinery Hengli Petrochemical (Dalian) Refinery Co., Ltd. — described as China's second-largest teapot — together with approximately 40 shipping firms and vessels operating as part of Iran's shadow fleet. OFAC sanctioned 19 shadow-fleet vessels (crude, LPG, and petrochemical tankers) as blocked property of designated owners or managers. The action was taken under Executive Order 13902 (Iran petroleum and petrochemical sectors) in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. Treasury press release SB0472. Concurrent with the designations, OFAC issued Iran-related General License W authorising the wind-down of transactions involving the persons newly blocked on May 1, 2026, and published a structurally novel Iran-related Alert, "Sanctions Risks of Iranian Demands for Strait of Hormuz Passage." The Alert states that payments to the Government of Iran or the IRGC — directly or indirectly — for safe passage through the Strait of Hormuz are not authorised for US persons (including US financial institutions) or US-owned/-controlled foreign entities. OFAC also issued new FAQ 1250 to accompany the Alert and GL W. The wave is one of the largest single-day Iran enforcement actions of the Trump 2.0 administration. Treasury characterises it as part of a campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The Strait of Hormuz Alert is the operational US response to Iranian regulatory threats against the ~20% of global oil and ~25% of global LNG transiting Hormuz, putting tanker owners, P&I clubs, flag states, and oil-buyer compliance teams on direct notice.

On April 24, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) added 19 entities and 19 vessels to the Specially Designated Nationals (SDN) List under Executive Order 13902 (Iran petroleum and petrochemical sectors), in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. The action is the first OFAC designation of a Chinese independent ("teapot") refinery — Hengli Petrochemical (Dalian) Refinery Co., Ltd., described as one of Iran's largest single customers for crude oil and petroleum products, having purchased billions of US dollars' worth since at least 2023 from cargoes brokered by Sepehr Energy Jahan Nama Pars Company (the oil sales arm of Iran's Armed Forces General Staff, controlled by the Ministry of Defense / MODAFL). Co-designations span shipping firms and vessels registered in China, Hong Kong, Panama, Marshall Islands, Liberia, and Vietnam. Concurrent with the designations, OFAC issued Iran-related General License V authorising a 30-day wind-down (through May 24, 2026) of transactions involving Hengli Petrochemical (Dalian) Refinery Co., Ltd. and certain majority-owned entities. Treasury press release SB0472 ("Economic Fury Targets Global Network Fueling Iran's Oil Trade and Shadow Fleet") frames the action as part of the maximum-pressure campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The April 24 designations directly triggered the first-ever operational use of China's Blocking Rules (MOFCOM Announcement No. 21 of May 2, 2026) and preceded a second OFAC Iran wave on May 1, 2026 (General License W + Strait of Hormuz Sanctions Risk Alert).

President Ilham Aliyev signed Decree No. 649 on 20 April 2026, transferring eight named limestone and sand-gravel deposits across six Azerbaijani districts (Garadagh/Baku, Absheron, Zagatala, Balakan, Oghuz, Imishli) to state-owned AzerGold CJSC, extending the state mining champion's mandate beyond precious metals into non-metal construction aggregates previously licensed to private operators. The decree also establishes a "Digital Ecology" single-window e-licensing system — effective 1 August 2027 — for all non-oil-gas subsoil-use activities including rights-granting, state expertise, operator reporting, and auction/tender organisation, replacing Azerbaijan's fragmented licensing regime. Cabinet of Ministers is directed to develop proposals on strengthened operator liability and monitoring systems within three and six months respectively, creating an implementing-regulations pipeline through end-2026.

ALNAFT officially launched the Algeria Bid Round 2026 on 19 April 2026 in Algiers, offering seven onshore exploration/development perimeters (Est Bordj Omar Driss I, Illizi Centre I, El M'Zaid Nord, El Borma II, El Hadjira III, El Benoud Est, Touggourt Sud) located in the Ouargla, Illizi, Touggourt, and El Bayadh hydrocarbon provinces. The round operates under the Loi n° 19-13 hydrocarbons framework, with the virtual data room (VDR) opening 1 June 2026, bids due 26 November 2026, and contracts to be signed no later than 31 January 2027. The initiative is Algeria's first structured multi-block bid round since the 2019 framework law restructured the upstream contractual and institutional architecture, and is materially significant to EU gas-import diversification given Algeria's approximately 12% share of EU gas supply via the Medgaz and Transmed pipelines plus LNG.

On March 20, 2026, OFAC issued Iran-related General License U (GL U), temporarily authorizing the sale, delivery, offloading and — notably, for the first time in decades — importation into the United States of Iranian-origin crude oil and petroleum products, but only for cargo already loaded onto vessels as of 12:01 a.m. EDT that day. The window ran through April 19, 2026, after which the authorization lapsed. The license excluded any transaction touching Cuba, North Korea, or Russian-government-controlled areas of Ukraine, and did not waive any other, non-Iran sanctions program. OFAC formally published GL U (and the separate, entity-specific GL V wind-down license for Hengli Petrochemical) in the Federal Register on June 10, 2026 — a retrospective publication of licenses already issued and, by then, already expired.

On 12 March 2026 Senegal's Primature held a press conference releasing mid-term findings of the National Commission for the Re-evaluation and Renegotiation of Petroleum, Gas, and Mining Contracts, created in August 2024 under Prime Minister Ousmane Sonko's reform programme. The Commission identified a 1,075.9 billion FCFA shortfall in the mining sector — concentrated in unpaid taxes/royalties and unauthorised tax exemptions at ICS (Industries Chimiques du Sénégal) — and announced the termination of four offshore oil-exploration blocks (Djifer Offshore, Kayar Offshore, Saint-Louis Offshore, Rufisque Offshore). Renegotiation of the Greater Tortue Ahmeyim (GTA) gas project, operated by BP with Kosmos Energy and Woodside as partners on the Senegal-Mauritania maritime border, is under active examination; the Primature projects 900 bn FCFA in incremental fiscal revenue 2026-2040 from the contract revision programme. This is Senegal's first major instance of retroactive resource-contract review under the Sonko-Faye government and establishes the legal-political baseline for subsequent contract renegotiations across the 27 mining contracts and remaining hydrocarbon licences under Commission review.

Mozambique's Council of Ministers, at its 6th Ordinary Session on 3 March 2026, approved resolutions establishing two Interministerial Coordination Committees — one for the Development Plan of Area 1 of the Rovuma Block (the TotalEnergies-led Mozambique LNG project, formerly Anadarko) and one for Area 4 of the Rovuma Block (the ExxonMobil/Eni-led Rovuma LNG / Coral South / Coral Norte projects). Both committees are chaired by the Minister of Mineral Resources and Energy and include the ministers of finance, economy, transport and logistics, labour, and land and environment, plus INP, the Tax Authority, and the Bank of Mozambique as technical participants. The mandate is to monitor and ensure the rapid, coordinated government assessment of amendments to the development plans for these projects, which together represent approximately USD 50bn+ in committed capital in Cabo Delgado province and are the primary drivers of Mozambique's projected fiscal revenue stream through 2060+.

On 25 February 2026 the Swiss Federal Council adopted extensive amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (Ukraine Ordinance) and the Ordinance on Measures against Belarus, completing implementation of the EU's 19th sanctions package with effect from 26 February 2026. Headline measures: a complete ban on the purchase and import of Russian LNG taking effect 25 April 2026 (transition period until end-2026 for pre-existing long-term contracts); a complete prohibition on the provision of crypto-asset services to Russian persons and companies; new service bans covering advanced-technology / AI / high-performance-computing services and tourism-related services; expansion of the dual-use end-user list (Annex 2) including additional Chinese entities; SECO authority to grant divestment-exemption licences until end-2026 under Art. 30a; and parallel adoption of the EU October 2025 Belarus measures via amendment to the Belarus Ordinance.

On 13 February 2026 President Bola Ahmed Tinubu signed Executive Order No. 9 of 2026 directing all Production Sharing Contract operators and contractors to remit Royalty Oil, Tax Oil, Profit Oil, and Profit Gas directly to the Federation Account, bypassing prior NNPC Limited intermediated collection. The order simultaneously eliminates NNPC Limited's 30% management fee on profit oil/gas, suspends the 30% Frontier Exploration Fund deduction, and redirects Gas Flare Penalty proceeds to the Federation Account — materially walking back the fiscal architecture established under Petroleum Industry Act 2021 §§ 9 and 53. An Implementation Committee chaired by the Minister of Finance was established to operationalise the order and resolve disputes.

President Trump signed Executive Order 14382, "Addressing Threats to the United States by the Government of Iran," on 6 February 2026 (effective 12:01 a.m. EST on 7 February 2026; published in the Federal Register on 11 February 2026 as FR doc 2026-02813, 91 FR 6493-6496). Invoking IEEPA, the National Emergencies Act, section 604 of the Trade Act of 1974 and 3 U.S.C. § 301, the order declared a country-specific national emergency with respect to Iran and established a secondary-tariff-authority framework: an additional ad valorem duty (the EO offers "for example, 25 percent" as illustration but sets no binding rate) is authorised on imports of articles produced by any foreign country determined to directly or indirectly purchase, import, or otherwise acquire any goods or services from Iran. Determinations are made by the Secretary of Commerce, with rate recommendations from the Secretary of State in consultation with Treasury, DHS and USTR; the President retains final authority. EO 14382 was structurally modelled on EO 14245 (Venezuelan oil importing countries, 24 March 2025) and EO 14380 (Cuba, 29 January 2026), and was on the list of nine IEEPA-based tariff EOs whose tariff component was vacated by the SCOTUS 6-3 ruling in *Learning Resources, Inc. v. Trump* (20 February 2026). The companion EO 14389 of 20 February 2026 ("Ending Certain Tariff Actions") extinguished the tariff authority for entries on or after 12:00 a.m. ET on 24 February 2026; the underlying Iran national- emergency declaration was preserved. No third-country determination or specific rate was operationalised under EO 14382 prior to vacatur.

President Trump signed Executive Order 14380, "Addressing Threats to the United States by the Government of Cuba," on 29 January 2026 (effective 12:01 a.m. EST on 30 January 2026; published in the Federal Register on 3 February 2026 as FR doc 2026-02250, 91 FR 5085-5089). Invoking IEEPA and the National Emergencies Act, the order declared a country-specific national emergency with respect to Cuba, citing Havana's intelligence and defense alignment with Russia, the PRC, Iran, Hamas and Hezbollah — including the Russian signals-intelligence facility hosted on the island. The operative measure was a secondary-tariff-authority framework: the EO authorises additional ad valorem duties on goods imported from any country determined to be selling or otherwise providing oil to the Government of Cuba, whether directly or indirectly. No specific rate was set in the EO itself — rate-setting was delegated to the Secretary of Commerce (in consultation with State, Treasury, DHS and USTR). The EO was structurally analogous to EO 14245 (Venezuelan oil importing countries, 24 March 2025) and was on the list of nine IEEPA-based tariff EOs whose tariff component was vacated by the SCOTUS 6-3 ruling in *Learning Resources, Inc. v. Trump* (20 February 2026); the underlying Cuba national-emergency declaration was preserved by the 20 February 2026 "Ending Certain Tariff Actions" EO, but the tariff authority was extinguished before any third-country determination or rate was operationalised.

On January 23, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated eight vessel-owning/management firms — based in the UAE, India, Oman, the Seychelles, and the Marshall Islands — and identified nine of their tankers as blocked property, for transporting hundreds of millions of dollars' worth of Iranian crude oil, LPG, naphtha and high-sulfur fuel oil to buyers across East Asia, South Asia and East Africa. The action was taken under Executive Order 13902 (Iran petroleum/petrochemical sector) as part of the maximum-pressure campaign under National Security Presidential Memorandum 2, and OFAC concurrently issued General License T authorizing limited safety, environmental and cargo-offloading transactions involving the newly blocked vessels.

The US Treasury's Office of Foreign Assets Control designated 18 individuals and entities that make up the "rahbar" shadow-banking networks of sanctioned Iranian banks Bank Melli and Shahr Bank, including Singapore-based Golden Mist PTE Ltd, UAE-based Empire International Trading FZE and HMS Trading FZE, Iran-based Nikan Pezhvak Aria Kish Company and Tejarat Hermes Energy Qeshm, and UK-based Nanshan Ltd. Separately, OFAC designated senior Iranian security officials, including SCNS Secretary Ali Larijani, for their role in the regime's violent crackdown on peaceful protesters that began in December 2025. The financial designations were made under E.O. 13902 (Iran's financial/petroleum/petrochemical sectors) and the human-rights designations under E.O. 13553 and E.O. 13876, in furtherance of NSPM-2; Treasury noted it sanctioned more than 875 persons, vessels, and aircraft under the same maximum-pressure campaign in 2025.

On 26 December 2025, Japan's Cabinet approved the FY2026 (Reiwa 8) national budget, which the Global Trade Alert database logs as including a "Capital Investment in Oil and Natural Gas Field Exploration and Asset Acquisition Projects" financial-grant/equity line administered by METI, effective with the fiscal year on 1 April 2026. This continues the government's long-standing equity-investment scheme -- run through JOGMEC (the Japan Organization for Metals and Energy Security) -- that co-funds Japanese companies' upstream oil and gas exploration, development, and M&A/asset-acquisition activity abroad. The FY2026 initial-budget allocation for this specific line is JPY 42.7 billion, down from JPY 56.3 billion in FY2025, though a JPY 19.7 billion supplementary appropriation lifts total FY2026 availability to roughly JPY 62.4 billion -- a modest net increase over FY2025 once the supplementary tranche is included.

The Mexican federal government published the Programa Sectorial de Energía 2025-2030 (PMSE) in the Diario Oficial de la Federación on 22 December 2025, establishing a binding five-year state-led energy-planning mandate for the Sheinbaum administration (2024-2030). The PMSE mandates a 54-46 state-to-private electricity generation mix, sets a 35 GW new clean-generation target by 2030 (13.6 GW from CFE + 22 GW from private/state/community projects), and formally supersedes the prior market-led Estrategia Nacional de Energía 2018-2032 and PRODESEN architecture. The Program is legally mandatory for all federal public administration entities including CFE, PEMEX, CENACE, and CENAGAS, operationalising the 2024 constitutional reform that restored CFE and PEMEX to strategic-sector status under Articles 27 and 28 of the Constitution.

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.

On December 18, 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated 29 shadow-fleet vessels and 17 vessel-management/shipping firms — plus Egyptian businessman Hatem Elsaid Farid Ibrahim Sakr and two of his UAE-registered companies (Red Sea Ship Management LLC and High Seas Petroleum LLC) — under Executive Order 13902 for operating in Iran's petroleum sector. The vessels, flagged across Palau, Panama, Cook Islands, Barbados, Jamaica and unknown registries, are said to have transported "hundreds of millions of dollars'" worth of Iranian crude oil, fuel oil, bitumen, naphtha and condensate to buyers in Asia. Treasury frames the action as part of a campaign that has sanctioned more than 180 vessels since President Trump resumed office in January 2025, implementing NSPM-2 maximum-pressure policy.

On 5 December 2025, at the opening of the 14th Practical Nigerian Content Forum, Nigeria's Nigerian Content Development and Monitoring Board (NCDMB) unveiled a USD 100 million Equity Investment Scheme to provide equity and quasi-equity financing to high-growth indigenous energy service companies, diversifying the income base of the Nigerian Content Development Fund (NCDF). NCDMB Executive Secretary Engr. Felix Omatsola Ogbe and Bank of Industry Managing Director Dr. Olasupo Olusi signed an MOU under which BOI will manage the scheme as a new product of the Nigerian Content Intervention Fund, with a single-obligor limit of USD 5 million per investment. NCDMB also reported Nigerian content (local-participation) attainment reached 61% by Q3 2025.

The Ivorian Council of Ministers adopted on 3 December 2025 the Politique Intégrée des Ressources Minérales et de l'Énergie (PIRME), a 15-year cross-sector extractive and energy industrial-policy strategy requiring CFA 38,000 billion (~USD 68bn) across three five-year phases to 2040. The policy targets doubling the mining-energy sector's GDP contribution from 7% (2022) to 14% by 2040, positioning it as the economy's second pillar after agriculture. Core mandates include a 50% local transformation target for gold, a 10 million-tonne iron-ore production target, a 500,000 bbl/day oil production target, 45% renewable energy integration, and a 38% reduction in energy-sector emissions — backed by national-content and value-addition requirements across mining, hydrocarbons, and electricity sub-sectors.

Mozambique's Council of Ministers, at its 39th Ordinary Session on 18 November 2025, approved the terms and conditions of a concession contract granting a state-company consortium the exclusive right to finance, construct, import, and operate (i) a floating storage and regasification unit (FSRU) LNG terminal at Beira and Inhassoro (Inhambane province), and (ii) the 865-km ROMPCO gas pipeline connecting Mozambican gas fields to South Africa via Komatipoort — both for a 30-year concession term. The concessionaire is a Specific Object Entity (Entidade de Objecto Específico, EOE) constituted by four state enterprises — the National Hydrocarbon Company (ENH, E.P.), Mozambique Ports & Railways (CFM), Mozambique Electricity (EDM), and Cahora Bassa Hydroelectric (HCB) — plus government-selected technical and financial partners. The decree marks the first midstream LNG infrastructure-rights award in Mozambique and represents a foundational shift toward state-led control of the country's regasification and cross-border pipeline architecture rather than concession to international IOCs.

On 29 October 2025 the Swiss Federal Council amended the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), published as AS 2025 662, completing Switzerland's alignment with the remaining goods, finance and services elements of the EU's 18th Russia sanctions package (Council Regulation (EU) 2025/1494, 18 July 2025) and tightening the parallel Belarus regime. The amendment took effect 30 October 2025 and adds: an export ban covering additional structural-metal, general-purpose-machinery and machine-tool goods; an import ban on further petroleum-oil products and waste/scrap categories; and expanded controls on commercial transactions and investment instruments spanning financial services, investment banking, crude-petroleum trade and motor-vehicle/trailer goods. The Federal Department of Economic Affairs (WBF) had already taken over the measures within its own competence on 12 August 2025; this decision closes the remainder. In parallel, the Federal Council's asset-freeze annexes were extended to 14 individuals and 41 companies/organizations.

On October 22, 2025, the US Treasury's Office of Foreign Assets Control (OFAC) added Open Joint Stock Company Rosneft Oil Company ("Rosneft") and Lukoil OAO ("Lukoil") — together with dozens of named Russia-based subsidiaries — to the Specially Designated Nationals (SDN) List under Executive Order 14024 for "operating or having operated in the energy sector of the Russian Federation economy." It is the first US designation of Russia's two largest integrated oil majors since the 2022 invasion-era sanctions architecture began. Under OFAC's 50% Rule, the blocking extends automatically to all entities owned 50% or more, directly or indirectly, by Rosneft or Lukoil — capturing a sprawling global subsidiary network including Lukoil retail/refining assets in Belgium, Netherlands, Bulgaria, Romania, Italy, Finland, the West Qurna-2 upstream stake in Iraq, and Lukoil Americas. Rosneft and Lukoil together account for roughly half of Russian crude exports (~5 mb/d combined production) and Lukoil holds a ~9% European retail-fuel market share. OFAC simultaneously issued General License 124 (Caspian Pipeline Consortium / Tengizchevroil / Karachaganak Kazakhstan-pipeline carve-out, no expiry), General License 125 (Lukoil retail service stations outside Russia, wind-down to November 21, 2025), General License 126 (general wind-down to November 21, 2025) and General License 127 (debt/equity divestment and derivatives wind-down to November 21, 2025). GL 131 (issued November 14, 2025) opened a divestment window for Lukoil International GmbH; subsequent GL 134/134A/134B extended cargo-offload authorisations through April–May 2026. The action was coordinated same-day with UK OFSI Rosneft/Lukoil designations and the EU's 19th Russia sanctions package adopted October 23, 2025 — the first major US-led Russia-energy escalation under the second Trump administration.

On 15 October 2025 the UK Foreign, Commonwealth & Development Office, acting under the Russia (Sanctions) (EU Exit) Regulations 2019, designated 39 entities and specified 51 vessels — including, for the first time, Russia's two largest integrated oil majors PJSC Rosneft Oil Company and PJSC Oil Company Lukoil — for supporting Russia's energy, defence and financial sectors. 51 vessels (44 identified as "shadow fleet" tankers) were specified for transporting Russian crude oil and LNG in evasion of the G7 price cap. The package also introduced a ban on importing oil products refined in a third country from Russian-origin crude, closing a refined-product loophole in the price-cap regime.

On 9 October 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated more than 50 individuals, entities and vessels for facilitating Iranian crude oil, petroleum-product and liquefied petroleum gas (LPG) exports, in a coordinated action with the State Department. The network included 33 vessels transporting Iranian crude and LPG, shipping entities registered in Panama, the Marshall Islands, Ukraine and Liberia, an Iranian petrochemical producer, four Turkish petrochemical trading entities, five Chinese entities importing/refining/storing Iranian petroleum (including a China-based petrochemical-terminal operator, Jiangyin Foreversun Chemical Logistics Co., Ltd.), three Singapore-based logistics entities, and 27 entities based in Hong Kong, the UAE and India engaged in trading and shipping. The action was taken pursuant to the National Security Presidential Memorandum 2 (NSPM-2) maximum-pressure campaign against Iran and blocks all US property/interests of the designated parties, exposing non-US counterparties to secondary-sanctions risk.

The US Treasury's Office of Foreign Assets Control designated two Iranian financial facilitators — Alireza Derakhshan and Arash Estaki Alivand — along with more than a dozen Hong Kong- and UAE-based individuals and entities for operating a shadow-banking network that laundered proceeds from Iranian oil sales through front companies and cryptocurrency. The designated addresses account for over $600 million in total inflows, including more than $100 million in cryptocurrency purchases tied to oil sales between 2023 and 2025. Proceeds are alleged to benefit the IRGC-Qods Force and Iran's Ministry of Defense and Armed Forces Logistics (MODAFL). This is the second round of OFAC sanctions targeting Iran's shadow-banking infrastructure since National Security Presidential Memorandum 2 (NSPM-2) directed a maximum-pressure campaign on Iran in February 2025.

On 2 September 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated Waleed Khaled Hameed al-Samarra'i, a dual Iraqi/St Kitts-and-Nevis citizen, along with his UAE-based shipping manager Babylon and five Marshall Islands-registered shell companies (Tryfo Navigation, Keely Shiptrade, Odiar Management, Panarea Marine, Topsail Shipholding) that hold registered ownership of nine Liberia-flagged tankers (ADENA, LILIANA, CAMILLA, DELFINA, BIANCA, ROBERTA, ALEXANDRA, BELLAGIO, PAOLA). The network blends Iranian crude with Iraqi oil via ship-to-ship transfers in the Arabian Gulf and at Iraqi ports, then markets the blend as solely Iraqi-origin to evade US sanctions, generating hundreds of millions of dollars for the Iranian regime and al-Samarra'i. The action was taken pursuant to Executive Order 13902 and blocks all US property and interests of the designated individual, entities and vessels.

On 12 August 2025 the Swiss Federal Department of Economic Affairs, Education and Research (WBF) amended the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), published as AS 2025 497, adopting — within its own delegated competence and ahead of the full Federal Council decision — an interim tranche of measures aligning Switzerland with the EU's 18th Russia sanctions package (Council Regulation (EU) 2025/1494, 18 July 2025). The amendment lowers the Russian-crude price cap and updates the associated Annex 28 price-threshold table, extends export prohibitions on transport services, adds port-access restrictions covering 105 additional shadow-fleet vessels, and widens controls on commercial transactions and investment instruments for Russian financial institutions. It also extends asset-freeze listings to entities in China, Hong Kong, Singapore, Mauritius, Azerbaijan, India and the UAE implicated in circumvention. The measure took effect 12 August 2025. The Federal Council closed out the remaining goods, finance and services elements of the 18th package on 29 October 2025 (see responds_to).

On 30 July 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated more than 50 individuals and entities and identified more than 50 vessels belonging to the shipping empire of Mohammad Hossein Shamkhani, son of Ali Shamkhani, a top political adviser to Iran's Supreme Leader. Treasury described the action — over 115 sanctions in total — as its largest Iran-related action since 2018. The network launders billions of dollars from sales of Iranian and Russian crude oil and petroleum products (mostly to buyers in China) through vessels and front companies registered across the UAE, Hong Kong, India, Cyprus, Panama, Romania, China, Liberia, the Marshall Islands and Seychelles. Concurrently, the State Department designated 20 entities and identified 10 vessels under E.O. 13846 and E.O. 13902 for trading and transporting Iranian petroleum and petrochemical products.

On 26 June 2025 President Bola Ahmed Tinubu signed four acts constituting Nigeria's most comprehensive fiscal overhaul in decades: the Nigeria Tax Act 2025 (NTA), Nigeria Tax Administration Act 2025 (NTAA), Nigeria Revenue Service (Establishment) Act 2025, and Joint Revenue Board (Establishment) Act 2025. The NTA consolidates and repeals six core statutes — CITA, PITA, PPTA, VAT Act, CGT Act, and Stamp Duties Act — into a single unified code effective 1 January 2026, while the NTAA standardises assessment, filing, and enforcement procedures across all federal taxes. The two establishment acts restructure the Federal Inland Revenue Service (FIRS) into the Nigeria Revenue Service (NRS) with a broadened mandate and create an empowered Joint Revenue Board to coordinate federal-state fiscal relations.

At its 34th session in Harare on 5 June 2025, the SADC Committee of Ministers of Trade formally endorsed Angola's accession to the SADC Free Trade Area after Angola submitted its final tariff offer covering 90% of tariff lines — surpassing the SADC standard threshold of 85%. Angola becomes the 14th SADC member state to join the FTA, with implementation targeted for January 2026. The accession ends Angola's longstanding outlier status as the region's second-largest economy operating outside the bloc's duty-free zone, and opens tariff-free corridors between Angola and FTA members including South Africa, Zambia, DRC, Zimbabwe, and Mozambique.

Mozambique's Ministry of Mineral Resources and Energy (MIREME) published a comprehensive revision of the 2014 Petroleum Law (Lei n.º 21/2014) in June 2025, tabled before the Assembleia da República for debate on 7 May 2026. The revision mandates a minimum 25% domestic-market quota for all oil, gas, and LNG produced under concessions (exclusively for national consumption), requires 100% of condensate output to be allocated domestically, and introduces idle-block penalty charges for concessionaires that fail to develop assigned blocks within prescribed periods. It also elevates the Instituto Nacional de Petróleo (INP) to full Regulatory Authority status with inspection and sanctioning powers, and establishes a mandatory minimum state Participating Interest with a free-carry obligation through to commercial production.

President Bola Ahmed Tinubu signed the Upstream Petroleum Operations (Cost Efficiency Incentives) Order, 2025 on 29 May 2025, introducing a performance-based tax-credit framework for upstream oil and gas operators who beat NUPRC-set Unit Operating Cost benchmarks. Eligible lessees, licensees, and PSC contractors receive tax credits capped at 20% of their annual petroleum tax liability per licence area, applied against Petroleum Profits Tax, Hydrocarbon Tax, or Companies Income Tax. The Nigerian Upstream Petroleum Regulatory Commission (NUPRC) conducts annual terrain-specific (onshore, shallow-water, deep-offshore) Unit Operating Cost benchmarking, and the Federal Inland Revenue Service (FIRS) co-administers with claw-back provisions for non-compliance; the regime runs through 31 May 2035.

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.

On 8 May 2025, the US Treasury's Office of Foreign Assets Control designated China-based "teapot" refinery Hebei Xinhai Chemical Group Co., Ltd. and its Singapore-based broker subsidiary Xing AO Energy PTE. LTD., three firms tied to a Dongying Port (Shandong) terminal that has received Iranian crude from shadow-fleet tankers, and six Hong Kong-, UK-, and Marshall Islands-owned shadow-fleet vessels (STAR TWINKLE 6, LAMD, SKADI, BIG MAG, IMPALAS, THANE) plus their owning shipping companies and two vessel captains. It is OFAC's third action against an Iranian-oil teapot refinery and its first targeting Shandong port terminal operators, taken under E.O. 13902 (Iran petroleum/ petrochemical sector) and E.O. 13846 (NIOC support) as part of the administration's NSPM-2 maximum-pressure campaign.

On 30 April 2025 the US Department of State designated seven entities and identified two vessels as blocked property for facilitating trade in Iranian petroleum and petrochemical products, under Executive Order 13846 and in furtherance of National Security Presidential Memorandum 2 (NSPM-2, "Restoring Maximum Pressure on the Government of Iran"). The action named four UAE-based sellers and one purchaser of Iranian petrochemicals — including Solvent Organics (over $300 million in exports of Iranian-origin petrochemicals to third countries) and Alseerah Trading (over $150 million) — plus a Turkiye-based petrochemical trader, an Iran-based cargo inspection company, and a marine management company involved in transporting millions of barrels of Iranian crude. Secretary of State Marco Rubio stated the goal was to drive Iran's illicit oil and petrochemical exports, including to China, to zero.

Thailand's Cabinet approved in principle on 22 April 2025 the urgent revision of the Foreign Business Act B.E. 2542 (1999), directing the Ministry of Commerce to overhaul the foundational 25-year-old statute governing foreign participation in Thai economic activities, explicitly shifting the guiding principle from "protection" of domestic entrepreneurs to "enhancing competitiveness." In January 2026, the Department of Business Development operationalised the reform by announcing a 10-sector List-3 delisting package — including telecommunications services not owning network infrastructure, software development, financial-services categories (treasury centres, derivatives agency, collateralised lending, credit guarantee), petroleum drilling services, management services for affiliated companies, and domestic agricultural commodity trading — that would allow wholly-foreign-owned subsidiaries without a Foreign Business Licence (FBL). Simultaneously, the revision introduces a shift from a legal-shareholding test to an actual-control / beneficial-ownership test in nominee-shareholder enforcement, tightening the anti-front-company architecture while liberalising legitimate foreign-investment routes. Full statutory enactment via parliamentary process is expected mid-to-late 2026.

The Danish Energy Agency (Energistyrelsen) opened "Investeringsstøtten" (Investment Support), a DKK 1 billion grant pool running 2025-2030, targeting the CO2-intensive companies most exposed to Denmark's phased-in industrial CO2 tax. Eligible firms must emit on average at least 1,500 tonnes of CO2/year and see tax payments rise by at least 2.3% of gross value added under the new levy. In its first annual tranche (2025), the pool disbursed DKK 36 million, funding up to 60% of eligible costs at a rate of DKK 1,000 per tonne of CO2 abated for investments such as fossil-fuel boiler replacement with heat pumps or district heating. Qualifying sectors include general industrial processes, mineralogical processing, oil refining, domestic shipping ("indenrigssøfart" — including domestic ferries), and North Sea offshore activity. Legal basis is the "Aftale om Grøn skattereform for industri mv." (Green Tax Reform Agreement for Industry) of 22 June 2022, implemented via a Danish executive order (bekendtgørelse) on CO2-reduction subsidies for CO2-intensive enterprises, and notified to the European Commission under the General Block Exemption Regulation (EU) No. 651/2014.

Canada made SOR/2025-33, Regulations Amending the Special Economic Measures (Russia) Regulations, registered and effective 2025-02-21. The regulations add 32 individuals (Schedule 1, Part 1) and 44 entities (Schedule 1, Part 2) tied to Russia's military-industrial base, sanctions circumvention, disinformation and the forced deportation/filtration of Ukrainian children. A new Schedule 1.1 lists 109 vessels by IMO number — 92 oil tankers and 9 LNG tankers moving Russian energy exports to third countries, plus 8 vessels moving arms and related material between Russia, Iran and North Korea — banning their access to Canadian ports and waters and prohibiting dealings, asset provision and financial/other services in relation to them.

Mauritania promulgated Loi n° 2025-006 on 19 February 2025, comprehensively replacing the 2012 Investment Code (Loi n° 2012-052) with a three-tier incentive architecture — a Base Regime (SME + intermediate categories), a Development Poles Regime (designated geographic zones), and a Structuring Investments Regime (large-scale strategic projects above 200M MRU). The law was drafted with IFC/World Bank technical assistance, codifies national-treatment equality between domestic and foreign investors, provides fiscal-customs stability guarantees of up to 20 years, and establishes APIM as a digital single-window authority with ICSID/UNCITRAL arbitration pathways. As of July 2025, 19 projects (≈USD 120M declared investment, 939 estimated direct jobs) had been approved under the new framework.

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.

The Iraqi Council of Representatives adopted Law No. 4 of 2025 on 2 February 2025 (176 deputies present, majority vote), amending Article 12 of the Federal General Budget Law for Fiscal Years 2023-2024-2025 (Law No. 13 of 2023). The amendment mandates that the federal government pay international oil companies (IOCs) operating in the Kurdistan Region of Iraq (KRI) USD 16 per barrel in advance for crude production and transportation costs — more than doubling the USD 6/bbl rate in the original budget law — with all KRI crude to be delivered to and marketed exclusively through the State Organization for Marketing of Oil (SOMO). An international consulting firm, jointly appointed by Baghdad and Erbil within 60 days, is mandated to audit field-level production and transportation costs, with cost-recovery adjustments applied retroactively from the date pipeline flows resume. The law was published in the Iraqi Official Gazette (Al-Waqai al-Iraqiyya) Issue No. 4814 on 17 February 2025.

President Trump signed Executive Order 14154 "Unleashing American Energy" on 20 January 2025, his first day in office, declaring a national energy emergency and directing a sweeping reversal of Biden-era energy trade and production restrictions. The order directed the Department of Energy to immediately resume processing LNG export licence applications for non-Free Trade Agreement countries — reversing the Biden DOE pause in place since 26 January 2024 — and instructed DOE to weight allies' energy security in the "public interest" determination under the Natural Gas Act. It also rescinded multiple Biden executive orders including EO 14082 (advancing clean energy), EO 14037 (strengthening Buy American), EO 14072, and EO 14151, and reopened offshore drilling, federal coal leasing, and ANWR exploration under expedited permit timelines.

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.