The Office of Foreign Assets Control (“OFAC”) designated Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Public Joint-Stock Company Oil Company Lukoil (“Lukoil”) on October 22, 2025, in response to the ongoing war in Ukraine. In announcing the designations under Executive Order (“EO”) 14024, Secretary of the Treasury Scott Bessent stated that the actions were taken to advance the administration’s goal of ending the war in Ukraine by targeting two of Russia’s largest oil companies that had to date been excluded from a range of sanctions designations targeting other Russian companies. The designations announced by OFAC included not just Rosneft and Lukoil, but also a number of their subsidiaries operating in the energy sector of the Russian economy. Our blog post on the joint designations of Rosneft and Lukoil from the EU, UK, and US can be found here.
In connection with the new designations, OFAC issued several new or amended general licenses authorizing certain activities with Rosneft, Lukoil, and their majority-owned direct or indirect subsidiaries that would otherwise be prohibited by EO 14024 and amended FAQ 1216. The new and amended general licenses include:
- General License 124A: This general license (“GL”) amends GL 124 that was issued on May 15, 2025, to authorize the provision of certain petroleum services and other transactions to only Rosneft, Lukoil, and their respective majority owned direct and indirect subsidiaries in connection with the Caspian Pipeline Consortium and the Tengizchevroil projects.
- General License 126: This general license authorizes transactions that are ordinarily incident and necessary to the wind-down of transactions involving Rosneft, Lukoil, and their respective majority owned direct and indirect subsidiaries before November 21, 2025. Payments to Rosneft, Lukoil, and/or their direct or indirect majority-owned subsidiaries may only be made to blocked accounts in the name(s) of such blocked persons.
- General License 127: This general license authorizes certain transactions related to debt or equity of, or derivative contracts involving Rosneft, Lukoil, and/or their direct or indirect majority-owned subsidiaries. Specifically, the general license authorizes all transactions ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity in Lukoil, Rosneft, or their respective direct or indirect majority-owned subsidiaries. The authorization applies only to debt or equity that was in place prior to 4pm ET on October 22, 2025, and is valid only until November 21, 2025.
- General License 128: This general license authorizes certain transactions involving Lukoil Retail service stations located outside of Russia that existed on or before October 22, 2025, during a brief wind-down period that is valid until November 21, 2025. The general license requires that any payments to Lukoil Retail service stations authorized by this general license be paid into blocked accounts.
- General License 129: This general license authorizes transactions involving two German subsidiaries of Rosneft: Rosneft Deutschland GmbH and RN Refining & Marketing GmbH, as well as their direct and indirect majority-owned subsidiaries. The general license authorizes applicable transactions until April 29, 2026.
These latest actions reflect ongoing attempts by the current administration to apply pressure to key sectors and companies of the Russian economy to resolve the war in Ukraine, while allowing for ongoing activities with certain projects in which US and allied country companies have a significant and ongoing interest (such as the Caspian Pipeline Consortium and the Tengizchevroil projects). We are closely monitoring these developments and will continue to provide updates to this blog as and when new actions are taken.
