On October 22, 2025, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury designated OJSC Rosneft (Rosneft) and Lukoil OAO (Lukoil) on the List of Specially Designated Nationals and Blocked Persons (SDN List, and persons thereon, SDNs). OFAC also designated 34 subsidiaries of Rosneft and Lukoil. All targeted entities were designated pursuant to Executive Order 14024 for operating or having operated in the Russian energy sector.
US person prohibitions
As a result of the designation, US persons (for these purposes, US citizens and permanent residents, entities organized under US law, and natural persons while physically present in the United States) are prohibited from engaging in virtually any transactions with or for the benefit of Rosneft or Lukoil, as well as any subsidiaries that are ultimately owned 50% or more by Rosneft or Lukoil (regardless of whether such subsidiaries were separately designated as SDNs or not), or another SDN. All property and interests in property of Rosneft, Lukoil, and their 50%-or-more owned subsidiaries that is or comes within the possession or control of US persons must be blocked (i.e., frozen).
Sanctions risk for non-US entities
Pursuant to Executive Order 14024, OFAC may also designate any person that is deemed to have “materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of” any of the newly-sanctioned entities. Consequently, non-US entities that engage in transactions with or for the benefit of Rosneft or Lukoil may risk becoming sanctioned themselves. Further, US and other financial institutions and corporations may be reluctant to transact with entities that engage in business with Rosneft or Lukoil or their subsidiaries.
General licenses
Concurrently with the new sanctions designations, OFAC issued general licenses authorizing certain transactions that would otherwise be prohibited. These include:
- GL 124A, authorizing otherwise-prohibited transactions related to the Caspian Pipeline Consortium or Tengizchevroil projects;
- GL 126, authorizing transactions ordinarily incident and necessary to the wind down of any transactions involving Rosneft, Lukoil, or their 50%-o-more ultimately owned subsidiaries, until November 21, 2025;
- GL 127, authorizing transactions ordinarily incident and necessary to the divestment or transfer, or facilitation thereof, of debt or equity issued or guaranteed by Rosneft, Lukoil, or their 50%-or-more ultimately owned subsidiaries, until November 21, 2025; and
- GL 128, authorizing transactions involving Lukoil retail service stations located outside the Russian Federation, until November 21, 2025.
Perhaps most importantly, entities engaged in business with Rosneft, Lukoil, or their 50%- or-more ultimately owned subsidiaries thus have until November 21, 2025 to wind down these transactions, subject to the terms of GLS 126 and 127, without risking sanctions violations or designations.
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