The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 14 Nov 2025 (OFAC):
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued Russia-related General Licenses ("GLs") 124B ("Authorizing Petroleum Services and Other Transactions Related to the Caspian Pipeline Consortium, Tengizchevroil, and Karachaganak Projects"); 128A ("Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia"); 130 ("Authorizing Transactions Involving Certain Lukoil Entities in Bulgaria); and 131 ("Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities").
- 14 Nov 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2025/7895596 ("GL INT/2025/7895596" or the "GL"), pursuant to the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations"). Capitalized terms not otherwise defined in this entry shall have the meanings given to such terms in the GL. The GL allows Persons to continue business operations involving the Lukoil Bulgaria entities, which are subsidiaries of UK designated person, PJSC Oil Company Lukoil.
- 14 Nov 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") added one FAQ (FAQ 173) to the UK's Financial Sanctions FAQs, which relates to the continuation of business operations with Lukoil Bulgaria EOOD and Lukoil Neftochim Burgas AD, pursuant to General Licence INT/2025/7895596 ("GL INT/2025/7895596" or the "GL").
- 13 Nov 2025 (UK):
The National Crime Agency ("NCA"), together with the Office of Financial Sanctions Implementation ("OFSI") and the Foreign, Commonwealth and Development Office ("FCDO"), issued an Amber Alert typology to promote awareness of, and encourage preventative action against, sophisticated sanctions evasion mechanisms adopted by 'Networks and Shadow Fleets' (the "Alert").
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