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

The Council of the EU adopted Council Regulation (EU) 2023/2878 of 18 December 2023, the EU's 12th sanctions package against Russia, entering into force 19 December 2023. The package introduces a direct EU import ban on Russian non-industrial natural and synthetic diamonds and diamond jewellery effective 1 January 2024, followed by a phased indirect ban on Russian diamonds processed in third countries (from 1 March 2024, complete by 1 September 2024), developed as part of a G7-coordinated diamond restriction. The package also extends import bans on steel and other products generating significant revenue for Russia, and adds further trade and economic restrictions.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) reached a $968,618,825 settlement with Binance Holdings, Ltd. — a Cayman Islands–domiciled virtual-currency exchange — to resolve civil liability for 1,667,153 apparent violations of multiple sanctions programs (Iran, Cuba, North Korea, Syria, and the Crimea region of Ukraine) committed between August 2017 and October 2022. OFAC determined the apparent violations were not voluntarily self-disclosed and that Binance's conduct was egregious; the settlement requires a five-year independent compliance monitor and was announced concurrently with parallel DOJ, FinCEN, and CFTC resolutions totaling approximately $4.3 billion in aggregate (including criminal forfeiture and BSA/AML penalties), alongside a separate criminal plea by founder Changpeng Zhao. The settlement is the largest civil monetary penalty in OFAC's history.

On 18 October 2023 the Governor in Council registered Regulations Amending the Special Economic Measures (Iran) Regulations (SOR/2023-220) under the Special Economic Measures Act, citing Iran's proliferation- sensitive nuclear activities and weapons-of-mass-destruction-related programme as a grave breach of international peace and security. The amendment prohibits Canadians and Canadian entities from exporting, selling or supplying to Iran dual-use goods and technology, conventional arms (battle tanks, armoured combat vehicles, large-calibre artillery, combat aircraft, attack helicopters, warships), Missile Technology Control Regime-listed equipment, and technical data related to ballistic missiles and nuclear-weapon delivery systems; it also bars importing arms and related material from Iran. The same instrument adds 156 entities and 18 individuals to Canada's Iran sanctions list (asset freeze / dealings prohibition).

The U.S. Treasury's Office of Foreign Assets Control (OFAC) issued a determination pursuant to Section 1(a)(i) of Executive Order 14014 identifying the jet fuel sector of the Burmese economy as a sanctions-eligible sector. The determination means that foreign persons who operate in Burma's jet fuel sector — including activities related to importation, exportation, reexportation, sale, supply, or transport of jet fuel in or involving Burma — may be designated and sanctioned by OFAC. Issued on the OFAC website on August 23, 2023 and formally published in the Federal Register on September 25, 2023 (FR Doc 2023-20713), the action was accompanied by concurrent SDN designations targeting key figures in the SAC junta's jet-fuel supply network.

On 16 August 2023 the Swiss Federal Council amended the Ordinance of 4 March 2022 on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), aligning with the EU's 11th Russia sanctions package. The amendment adds two UAE-headquartered firms to the list of entities barred from exemptions to Switzerland's dual-use export ban on Russia, restricts the sale of securities issued after 6 August 2023 to Russian nationals, residents, entities and businesses regardless of currency, and adds 12 individuals and 87 entities to the asset-freeze list, targeting dual-use/military-tech exporters, FSB-licensed IT firms, propagandists and government officials. It entered into force the same day at 18:00 CEST.

Poland's Minister of Development and Technology, Waldemar Buda, established a temporary compulsory administrator (tymczasowy zarządca przymusowy) over the Grupa Azoty S.A. shares held by sanctioned Russian oligarch Vyacheslav Kantor through three holding vehicles — Norica Holding S.à r.l. (Luxembourg), Opansa Enterprises Limited and Rainbee Holdings Limited (both Cyprus) — which together controlled 19.82% of the state-linked fertiliser and chemicals group, worth over PLN 0.5bn. The ministry cited Kantor's inclusion on Poland's sanctions list and the protection of the country's economic and energy security, and stated its intent to find a buyer for the stake and compensate Kantor. The Provincial Administrative Court in Warsaw (WSA) later overturned the decision establishing the administration; the ministry did not appeal, and the ruling became final around 30 July 2024, ending the administrator's mandate — though the underlying EU/Polish sanctions on Kantor continue to freeze his ability to exercise any rights attached to the shares.

OFAC issued the Hostages and Wrongful Detention Sanctions Regulations, 31 CFR Part 526, as a final rule effective July 11, 2023, implementing the portions of Executive Order 14078 ("Bolstering Efforts To Bring Hostages and Wrongfully Detained United States Nationals Home", July 19, 2022) administered by the Treasury. The regulations authorise blocking of the property and interests in property of any foreign person determined by the Secretary of State to be responsible for, or complicit in, the hostage-taking or wrongful detention of a US national abroad, with IEEPA as the underlying authority. This is a framework/enabling regulation: it codifies the prohibitions, the 50% ownership rule, evasion-prohibition, and the licensing architecture — individual designations under the program appear on the SDN List.

On 23 June 2023 the Council of the European Union adopted Council Regulation (EU) 2023/1214, amending Regulation (EU) No 833/2014 and comprising the EU's 11th Russia sanctions package. It extends the list of goods generating significant revenue for Russia subject to import bans, adds further export-ban categories (including additional industrial goods, dual-use and advanced-technology items), and introduces a new anti-circumvention tool (Article 12g) allowing the EU to restrict exports of specified sanctioned goods and technology to third countries assessed as high-risk transshipment routes for Russia. Asset-freeze listings under the parallel Council Decision took effect 23 June 2023; the sectoral trade measures took effect 24 June 2023.

OFAC replaced the abbreviated July 2014 South Sudan Sanctions Regulations (31 CFR Part 558) with a comprehensive final rule that adds interpretive guidance, definitions, and general licenses while implementing the full set of prohibitions in Executive Order 13664 of April 3, 2014. The rule does not expand the underlying blocking authority or add new designations; it codifies the existing program in a complete regulatory framework accessible to the public and regulated community. Target: persons threatening South Sudan's peace, security, or stability, obstructing the Comprehensive Peace Agreement, or responsible for human rights abuses or conflict-mineral trade that finances armed groups.

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.

Canada registered SOR/2023-46 on 2023-03-10, amending the Special Economic Measures (Russia) Regulations to add section 3.14 and a new Schedule 11. The section prohibits any person in Canada, and any Canadian outside Canada, from importing, purchasing or acquiring the listed steel and aluminum goods from Russia or from any person in Russia. Schedule 11 covers HS Chapter 72 (iron and steel), HS 7301-7306 (sheet piling, railway material, tubes, pipes and profiles) and aluminum products. Goods under a contract entered into before the regulations came into force are exempt; the regulations took effect on registration.

On 25 February 2023, one year into Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Council Regulation (EU) 2023/427, the 10th package of sanctions, amending Regulation (EU) 833/2014. It entered into force on publication the following day (26 February 2023). The package bans imports of asphalt and synthetic rubber from Russia (with a temporary transitional import quota for rubber products running to 30 June 2024), expands the export ban on dual-use and advanced-technology goods, suspends further Russian media broadcasting licences in the EU, and designates 87 individuals and 34 entities — including Iranian persons and entities involved in drone manufacture and supply, and 96 entities tied to Russia's defence-industrial base — to the EU asset-freeze/travel-ban list.

On 24 February 2023, to mark the one-year anniversary of Russia's full-scale invasion of Ukraine, the UK government announced a new sanctions package including an import ban on over 140 goods (including iron and steel products processed in third countries), an export ban on battlefield-relevant goods, and 92 new asset-freeze designations. The measures were legislated by the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023 (SI 2023/440), which came into force on 21 April 2023, except the third-country-processed iron and steel import provision (Regulation 3), which came into force on 30 September 2023.

On 24 February 2023, the first anniversary of Russia's full-scale invasion of Ukraine, the US Department of State announced a package of sanctions designations under the executive order blocking property of persons engaged in harmful foreign activities of the Russian government (E.O. 14024). The State Department describes designating over 60 individuals and entities, including Russian officials and entities in Russia's advanced-technology sector, three enterprises that develop and operate Russia's nuclear weapons, and three civil nuclear entities within the Rosatom structure. The Treasury Department announced parallel designations, including four entities in the metals and mining sector.

On 24 February 2023 the US Treasury Department's Office of Foreign Assets Control (OFAC) announced sanctions on 22 individuals and 83 entities, which Treasury describes as targeting key sectors, evasion efforts and military supplies. Treasury issued a determination under Executive Order 14024 identifying the metals and mining sector of the Russian Federation economy as a sector subject to sanctions, and designated 11 Russian financial institutions, including Credit Bank of Moscow, plus Russian defence and advanced-materials enterprises and third-country evasion facilitators. General Licenses 60 and 61 authorise wind-down of dealings with newly blocked entities through 25 May 2023.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) designated Myanmar Mining Enterprise No. 1 (Monywa, Sagaing Region) and Myanmar Mining Enterprise No. 2 (Myitkyina, Kachin State) as Specially Designated Nationals pursuant to Executive Order 14014, finding both to be political subdivisions, agencies, or instrumentalities of the Government of Burma. Both enterprises are wholly owned by Burma's Ministry of Natural Resources and Environmental Conservation. The designations represent the first OFAC mining-sector SDN listings under the Burma sanctions program, completing the resource-sector sanctions picture that previously covered military conglomerates (MEHL/MEC), the gems enterprise (MGE), and oil and gas (MOGE via Directive 1). Mining Enterprise No. 2 in Kachin State is the state authority administering formal mining licensing across Burma's primary heavy rare-earth and jade production zone.

Switzerland's Federal Council amended the Ordinance on measures related to the situation in Ukraine (SR 946.231.176.72) to align with the EU's ninth sanctions package, effective 6pm on 25 January 2023. The amendment bans new Swiss investment, equity provision, and participation (including joint ventures) in Russian mining-sector entities, with a carve-out for critical raw materials (aluminium/bauxite, chromium, cobalt, copper, iron ore, mineral fertilisers, molybdenum, nickel, palladium, rhodium, scandium, titanium, vanadium). It also extends export bans on aerospace goods to aircraft and drone engines, adds new controls on dual-use and military/security-enhancement goods, bans product testing/advertising/market-research services to Russia, and designates roughly 200 additional individuals and entities, including the Russian Regional Development Bank, to frozen-asset lists.

FinCEN issued an order on 18 January 2023, published in the Federal Register on 23 January 2023 (FR Doc 2023-01189), prohibiting US covered financial institutions from transmitting funds to, from, or through Bitzlato Limited, a virtual-currency exchange incorporated in Hong Kong and identified as a primary money-laundering concern in connection with Russian illicit finance. The order invokes Section 9714(a) of the Combating Russian Money Laundering Act, as amended by Section 6106 of the National Defense Authorization Act for Fiscal Year 2022 (31 U.S.C. 5323). The action was coordinated with a DOJ criminal arrest of Bitzlato co-founder Anatoly Legkodymov and a parallel Europol/Eurojust-supported disruption of Bitzlato's infrastructure, effective 18 January 2023.