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On November 14, 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended two general licenses and issued two new general licenses (“GLs”)authorizing limited transactions involving Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Public Joint-Stock Company Oil Company Lukoil (“Lukoil”) and entities in which they respectively own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively “Rosneft and Lukoil Entities”). Rosneft and Lukoil…