On 10 January 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the UK’s Office of Financial Sanctions Implementation (“OFSI”) announced the designations of two major Russian oil companies, PJSC Surgutneftegas and Gazprom Neft. The US and the UK have introduced new general licenses to permit limited activity relating to these entities, detailed further below. OFAC also designated numerous energy sector parties and issued a new Russia-related petroleum services prohibition.…