The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 22 Oct 2025 (OFAC):
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") designated Open Joint Stock Company Rosneft Oil Company ("Rosneft") and Lukoil OAO ("Lukoil"), along with many of their subsidiaries, pursuant to E.O. 14024 for "operating or having operated in the energy sector of the Russian Federation economy."
Concurrently, OFAC issued Russia-related General License 124A, "Authorizing Petroleum Services and Other Transactions Related to the Caspian Pipeline Consortium and Tengizchevroil Projects"; Russia-related General License 126, "Authorizing the Wind Down of Transactions Involving Rosneft or Lukoil"; Russia-related General License 127, "Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Rosneft or Lukoil"; and Russia-related General License 128, "Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia."
- 22 Oct 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2025/7598960 ("GL INT/2025/7598960" or "GL"), pursuant to the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations"). The GL permits a Person to continue business operations involving the "Named Subsidiaries" (as defined by the GL) of the UK designated person, PJSC Rosneft Oil Company.
- 22 Oct 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") added one FAQ (FAQ 169) to the UK's Financial Sanctions FAQs, which relates to the continuation of business operations with the German subsidiaries of PJSC Rosneft Oil Company, pursuant to the Russia (Sanctions) (EU Exit) Regulations 2019.
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