Worldwide: Export Controls & Trade & Investment Sanctions

On November 15, 2025, the implementing regulation updating the EU's Dual-Use Regulation (Regulation (EU) 2021/821) came into force.

The Sanctions Update, compiled by attorneys from Steptoe's award-winning International Trade and Regulatory Compliance team and the Stepwise: Risk Outlook editorial team, publishes every Monday.

General Motors (GM) has instructed thousands of its suppliers to phase out sourcing parts and materials from China by 2027.

On 23 October 2025, the Council of the European Union announced the 19th EU package of sanctions against Russia, reflecting the continued commitment of the European Union to respond to the ongoing conflict in Ukraine...

As multilateral development banks (MDBs) mark the 15th anniversary of their cross‑debarment agreement, enforcement of integrity breaches in connection with MDB-financed projects is both broader...

On November 10, 2025, the U.S. Departments of the Treasury, Commerce, and State issued a Tri-Seal Compliance Note (the "Note") outlining the scope of recent U.S. sanctions...

On November 1, 2025, the White House formally announced in a fact sheet that the United States will suspend the Bureau of Industry and Security's 50% rule...

On October 22, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") designated two of Russia's largest oil companies—Open Joint Stock Company Rosneft Oil Company ("Rosneft") and Lukoil OAO ("Lukoil")—and certain of their subsidiaries as Specially Designated Nationals ("SDNs").

Intended to increase pressure on Russia's energy sector and degrade a source of revenue for the war in Ukraine, this action will have broad implications for international energy markets.