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 and certain of their subsidiaries were designated as Specially Designated Nationals (“SDNs”) on October 22, 2025. Our blog post on the SDN designations of Rosneft and Lukoil can be found here.
The amended and new GLs are the following:
- General License 124B amended GL 124A of October 22, 2025 to include the Karachaganak project (in addition to the Caspian Pipeline Consortium and the Tengizchevroil projects) as among the projects with respect to which the provision of certain petroleum services and other transactions are authorized as to Rosneft and Lukoil Entities.
- General License 128A extended the validity of GL 128 to authorize transactions that are ordinarily incident and necessary to the purchase of goods and services from, or the maintenance, operation, or wind down of Lukoil retail service stations located outside of Russia that existed on or before October 22, 2025, until 12:01 a.m. eastern standard time on December 13, 2025.
- General License 130 authorizes all transactions with the following four Lukoil entities incorporated in Bulgaria, and any entity in which such entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, until 12:01 a.m. eastern standard time on April 29, 2026: Lukoil Neftohim Burgas JSC, Lukoil Bulgaria EOOD, Lukoil Aviation Bulgaria EOOD, and Lukoil Bulgaria Buner EOOD.
- General License 131 authorizes, through 12:01 a.m. eastern standard time on December 13, 2025, all transactions that are ordinarily incident and necessary to (1) the negotiation of and entry into contracts with Lukoil or any of its affiliates for the sale, disposition, or transfer of Lukoil International GmbH (“LIG”) or any entity in which LIG owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively, “LIG Entities”), provided that the performance of any such contract is made expressly contingent upon the receipt of separate authorization from OFAC, and (2) the maintenance or wind down of operations, contracts or other agreements of LIG entities.
We continue to closely monitor Russia sanctions developments and will continue to post updates to this blog.
