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

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.

The National Upstream Petroleum Local Content Policy (NUPLCP), approved by Namibia's Cabinet in December 2024 and finalised by the Ministry of Mines and Energy in March 2025, requires all upstream petroleum operators to submit Local Content Plans detailing Namibian workforce hiring, skills transfer, and local supplier engagement commitments as a condition of exploration and production licences. The policy is the primary industrial-policy instrument governing Namibia's nascent offshore oil sector, targeting the Orange Basin deepwater blocks (PEL 39, PEL 56, PEL 83, PEL 85, PEL 90, PEL 91) where Shell, TotalEnergies, Galp, Chevron, ExxonMobil, and QatarEnergy have confirmed ~11+ billion barrels of recoverable resource with a 2027–2029 FID horizon and projected peak output of ~700 kbpd by 2030+. Enforcement is initially guidance-based with a dedicated monitoring framework under development; critics note weak enforcement infrastructure as the principal implementation risk.

Angola's President João Lourenço signed Decreto Presidencial n.º 271/20 on 20 October 2020, replacing Order n.º 127/03 of 2003 and establishing the Regime Jurídico do Conteúdo Local do Sector dos Petróleos (RJCLSP). The decree divides petroleum-sector contracting into three regimes — exclusivity (reserved for Angolan nationals and companies), preference (Angolan-majority bidders take priority), and open competition with mandatory local-content scoring — covering all goods and services contracts entered into by concessionaires and their full subcontracting chains. The Ministério dos Recursos Minerais, Petróleo e Gás (MIREMPET) supervises compliance, with non-inclusion of mandatory local-content clauses penalised at USD 50,000–200,000 per infraction and escalating to contract cancellation for repeat offenders. The RJCLSP applies to all IOCs operating Angolan offshore blocks, including TotalEnergies (Block 17), ExxonMobil (Block 15), Chevron (Blocks 0, 14, 14K), BP (Block 31), Eni (Blocks 2, 14, 15/06), and Equinor, as well as their oilfield-services subcontractor chains.

Senegal's National Assembly adopted Loi n° 2019-04 on 24 January 2019 and President Macky Sall promulgated it on 1 February 2019, establishing the foundational legal framework for maximising Senegalese participation across the entire hydrocarbon value chain — from exploration through decommissioning. The law creates three activity-classification regimes (exclusif, mixte, non-exclusif), mandates priority employment of Senegalese workers, and creates two implementing bodies: the Comité National de Suivi du Contenu Local (CNSCL, via Décret 2020-2046) and the Fonds d'appui au développement du contenu local (FADCL, via Décret 2020-2048). It underpins all petroleum contracts under which Petrosen, Woodside (Sangomar, first oil June 2024), bp/Kosmos (GTA Tortue Ahmeyim, first gas December 2024), and future Yakaar-Teranga development licenses operate.