Industrial Policy & Trade Monitor· 2662 actions· ✨ 89 recent

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 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.

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).

Kazakhstan's Ministry of Energy extended its ban on the export of petroleum products — including gasoline, diesel, aviation kerosene, gasoil, toluene, xylene, bitumen, and LPG — for a further six months from May 21 to November 21, 2026. The restrictions apply to exports by road and rail, including shipments to fellow EAEU member states. The measure continues a rolling domestic-price-stabilisation regime that has been renewed since at least 2024; the prior extension ran to May 20, 2026.

President Ferdinand R. Marcos Jr. signed Executive Order No. 110 on March 24, 2026, declaring a one-year State of National Energy Emergency in response to Middle East supply disruptions, including potential closure of the Strait of Hormuz, that threaten petroleum import flows to the Philippines. The order activates the Unified Package for Livelihoods, Industry, Food, and Transport (UPLIFT), suspends normal procurement requirements for emergency energy acquisition, grants the Department of Energy (DOE) emergency fuel-import authority, and releases a ₱20 billion emergency fund to secure fuel supply. The emergency regime also mandates accelerated renewable-energy transition and promotion of EVs in public transport to reduce long-run import dependency.

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.

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.

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 October 31, 2025, Bulgaria's National Assembly voted 135-4 (42 abstentions) to adopt a decision introducing a temporary measure restricting the export and intra-EU supply of petroleum products — chiefly diesel and aviation fuel — to all destinations, including fellow EU member states. The measure took effect around November 1, 2025 upon publication. Gasoline was excluded because domestic production exceeds internal demand. The ban is a direct domestic-supply-security response to US OFAC's October 22, 2025 SDN designation of Lukoil (see responds_to), whose Burgas refinery supplies roughly 80% of Bulgaria's fuel market; lawmakers cited the risk that sanctions exposure could disrupt Lukoil's export activity and drain the volumes needed to cover domestic demand. Exemptions cover refuelling of ships and aircraft and deliveries to NATO and EU member-state armed forces under the common defence policy.

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 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.

Russia's government imposed a temporary ban on exports of diesel fuel, marine (bunker) fuel and other gas oils (EAEU HS codes 2710 19 421 0 - 2710 19 429 0), including volumes purchased on exchange trading, effective 1 October 2025. The measure was framed as a domestic fuel-market stabilisation tool and initially exempted direct refinery producers from the ban. Russia is one of the world's largest diesel/gasoil exporters, so a full-coverage export halt on these grades has global gasoil-market significance, not just a regional effect. The ban has since been extended and tightened four times through mid-2026 (see amendments).

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 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 22 June 2025, Cambodian Prime Minister Hun Manet ordered an immediate and complete halt of all fuel and gas imports from Thailand, effective from midnight that night (00:00, 23 June 2025). The order came amid a rapidly escalating Cambodia-Thailand border dispute following the killing of a Cambodian soldier in a disputed border area the previous month, and followed Cambodia's closure of two land border checkpoints with Thailand the same day. Thailand exported an estimated 2.3 billion litres of fuel to Cambodia in 2024 — about 20% of Thailand's total fuel exports, worth roughly THB 48 billion (USD 1.5 billion) — making Cambodia one of the largest overseas markets for Thai state energy company PTT. Hun Manet stated Cambodian fuel importers have adequate capacity to source supply from alternative countries, and separately ordered strict legal penalties, including licence revocation, against any company found smuggling Thai-origin fuel into Cambodia.

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.

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.

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.

On 11 October 2024, the Secretary of the Treasury — acting in consultation with the Secretary of State and pursuant to section 1(a)(i) of Executive Order 13902 — determined that the petroleum and petrochemical sectors of the Iranian economy are sectors of strategic concern, exposing non-US persons that operate in or knowingly facilitate significant transactions with those sectors to secondary sanctions and SDN-listing risk. The determination was issued in response to Iran's 1 October 2024 ballistic- missile attack on Israeli targets and was formally published in the Federal Register on 19 November 2024 (FR Doc 2024-26800). Concurrent with the determination, OFAC designated an international network — including Sepehr Energy Jahan Nama Pars — that had shipped millions of barrels of Iranian crude on behalf of Iran's Armed Forces General Staff to the People's Republic of China.

Pakistan's Cabinet Committee on Energy approved the Oil Refining Policy 2023 for Upgradation of Existing/Brownfield Refineries on 7 August 2023, with Federal Cabinet ratification on 9 August 2023 and Petroleum Division notification to OGRA and refineries shortly thereafter. The policy provides a 7.5% deemed-duty incentive on locally-refined motor spirit (petrol) and high-speed diesel (with an additional 2.5% incremental incentive on HSD during the upgrade period) deposited into OGRA-managed escrow accounts to fund up to 27.5% of upgradation project cost, against a commitment by Pakistan's five brownfield refineries (PRL, NRL, ARL, PARCO, Cnergyico) to invest an estimated USD 4.5-6 billion to produce Euro-V compliant fuels. CCoE-approved amendments on 6 February 2024 extended the deemed-duty horizon to 20 years (or until petroleum-product price deregulation, whichever comes first) and tightened the framework for refineries that decline to sign Upgrade Agreements.

Switzerland's Federal Council amended the Ordinance on measures related to the situation in Ukraine (SR 946.231.176.72) to align with the remainder of the EU's tenth sanctions package, effective 8pm on 29 March 2023. The amendment extends the existing Russia import ban to additional petroleum products (including petroleum jelly and petroleum coke), bitumen/asphalt, bituminous mastics, carbon and synthetic rubber, adds further export controls and designations linked to drone transfers to Russia, and tightens reporting obligations in the financial sector.

Russian Government Resolution No. 506 of 29 March 2022, signed by Prime Minister Mikhail Mishustin and effective 30 March 2022, authorises the Ministry of Industry and Trade (Minpromtorg) to designate categories of goods exempt from articles 1252(4), 1359(6) and 1487 of the Russian Civil Code on national/regional exhaustion of trademark and other intellectual- property rights. Followed by Minpromtorg Order No. 1532 of 19 April 2022 publishing an initial list of 55 goods categories and named brands — including pharmaceuticals, electronics, automotive parts, mineral fuels, industrial chemicals, paper, textiles, base metals, and consumer goods — for which parallel (grey-market) imports without IP-holder consent are legalised. Designed as a sanctions-circumvention and supply-substitution instrument after the Western corporate exodus of March 2022; extended annually and most recently re-authorised through 31 December 2026.