Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

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.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) designated the Bhardwaj Human Smuggling Organization (Bhardwaj HSO), a Cancun, Mexico-based transnational criminal organization run by dual Indian-Mexican national Vikrant Bhardwaj, under Executive Order 13581 (as amended by EO 13863). The action names 21 designees in total — the organization, 4 individuals (including Bhardwaj's wife and a former Cancun airport police officer who provided access), and 16 front companies spanning Mexico, India and the UAE across real estate, construction, retail/hospitality, and tourism/transport sectors used to launder smuggling proceeds. The designation was coordinated with Homeland Security Investigations, the DEA, and Mexico's financial intelligence unit (UIF), and blocks all U.S. property and interests of the designees plus any entity 50%-or-more owned by them.

On 23 October 2025, the Council of the European Union adopted the 19th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/2033 amending Regulation 833/2014 (sectoral sanctions), Council Implementing Regulation (EU) 2025/2035 amending Regulation 269/2014 (asset-freeze listings — 22 individuals + 42 entities, total 69 listings), and Council Regulation (EU) 2025/2041 (parallel Belarus measures). The package closes the Russian-LNG import loophole left open by the 18th package and establishes the architectural template for crypto-asset sanctions. Headline measures: (i) full prohibition on imports of Russian-origin LNG into the EU — short-term contracts banned six months from entry into force (effective 25 April 2026), long-term contracts (> 1 year, executed before 17 June 2025) phased out by 1 January 2027; (ii) full transaction ban on Rosneft and Gazprom Neft (tightening prior partial measures); (iii) five additional Russian banks added to Annex XIV transaction ban (Alfa-Bank, MTS Bank among them; effective 12 November 2025); (iv) full transaction bans on the Mir card payment system and the Faster Payments System (SBP), effective 25 January 2026; (v) first-ever EU sanctions on a stablecoin — the rouble-backed A7A5 (issuer + developer designated) — and a Paraguay-based cryptocurrency exchange used as a circumvention rail; (vi) prohibition on EU operators contracting with 11 listed Russian Special Economic Zones (Annex LII), with mandatory divestment from Alabuga (Tatarstan) and Technopolis Moscow effective 25 January 2026 — no five-year wind-down available; (vii) 45 entities added to Annex IV military end-user list (28 Russian + 17 third-country: 12 Chinese/Hong Kong, 3 Indian, 2 Thai); (viii) new export restrictions on electronic components, microelectronics, acyclic hydrocarbons, pneumatic rubber tires and propellant chemicals (~EUR 155 m of EU 2024 exports); (ix) prohibition on supply of AI, HPC, and quantum-computing services to Russian persons (effective 25 November 2025); (x) tourism-services ban (1 January 2026 wind-down); (xi) 117 additional shadow-fleet vessels listed (cumulative 557, exceeding the 18th package's 444); (xii) four Belarus + Kazakhstan banks listed for SPFS use (effective 2 December 2025); (xiii) binding ownership/control definitions added to Reg. 269/2014 (50 % proprietary-rights threshold + eight-criterion control test). Entry into force on 24 October 2025 (day following publication in OJ L_202502033), except for measures with explicit deferred application dates.

Premier Li Qiang signed State Council Order No. 803 on 23 March 2025 promulgating the "Regulations on Implementation of the Anti-Foreign Sanctions Law of the People's Republic of China" (22 articles), effective on the date of publication (24 March 2025). The Regulations operationalise the 2021 Anti-Foreign Sanctions Law by clarifying the scope of countermeasure tools — explicitly extending "other property" subject to seizure to cash, bank deposits, securities, equity, intellectual property and accounts receivable, and listing the specific transaction and cooperation activities that may be prohibited or restricted (education, S&T, legal services, environment, trade, culture, tourism, health, sports, data and cross-border data transfers). They define inter-agency procedure, evidence and notice requirements for designations, and bind PRC organisations and individuals — including foreign-invested entities operating in China — to implement countermeasures, with sanctions including exclusion from government procurement, import/export and cross-border-data restrictions, and exit/stay restrictions for responsible persons.

OFAC final rule (FR Doc 2022-12445, 87 FR 35068) amending the Cuban Assets Control Regulations at 31 CFR Part 515 to implement elements of the Biden administration's May 16, 2022 Cuba policy announcement supporting the Cuban people. The rule reinstates the group people-to-people educational travel general license (suspended under the Trump administration) for organizations sponsoring exchanges that promote meaningful contact with Cubans and support civil society; removes the $1,000 quarterly limit on family remittances to close relatives in Cuba; authorizes donative remittances to Cuban nationals not affiliated with the government or Communist Party; and expands authorizations for professional meetings and conferences in Cuba. Effective June 9, 2022.

SOR/2022-28, registered and in force on 24 February 2022, amends the Special Economic Measures (Ukraine) Regulations to prohibit persons in Canada and Canadians abroad from making investments involving property in the so-called Donetsk People's Republic and Luhansk People's Republic regions, from importing, purchasing or acquiring goods from them, and from exporting goods destined for them. It also bars related financial services, technical assistance and tourism-related services. The prohibitions are territorial and apply to goods generally; no product list is itemised.

The US Treasury's Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (31 CFR Part 515) effective 24 September 2020 to further deny the Cuban regime revenue. The rule added a new prohibition on lodging at any property on the State Department's Cuba Prohibited Accommodations List (PAL) and removed the general licence permitting travellers to import Cuban-origin alcohol and tobacco products as accompanied baggage. It also narrowed the professional meetings and conferences general licence (515.564) and the public performances, clinics, workshops, competitions, and exhibitions general licence (515.575) to exclude Cuba-related activities, closing gaps exploited under earlier travel-authorisation categories.