On 22 October 2025 the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated two of Russia’s largest energy companies, Rosneft and Lukoil, as well as numerous of their subsidiaries, on the Specially Designated Nationals and Blocked Persons List (SDN List). Intended to increase pressure on Russia’s energy sector and degrade a source of revenue for the war in Ukraine, this action will have broad implications for international energy markets.
Designated pursuant to Executive Order 14024 for operating or having operated in the energy sector of the Russian economy, the companies added to the SDN List are now “blocked,” meaning that US persons are strictly prohibited from dealing directly or indirectly with them and must furthermore block (freeze) any property and property interests of these entities coming into their ownership or possession. Importantly, under OFAC’s “50% Rule,” any entities owned 50% or more directly or indirectly, whether individually or in the aggregate, by Rosneft, Lukoil, or their other designated subsidiaries must also be treated as blocked SDNs.
In conjunction with this action, OFAC issued four general licenses authorizing certain limited transactions involving Lukoil, Rosneft, and entities they own 50% or more directly or indirectly, whether individually or in the aggregate (collectively, the “Blocked Entities”):
- General License 126, authorizing through 12:01 a.m. EST, 21 November 2025, with limited exceptions, transactions ordinarily incident and necessary to the wind-down of transactions involving the Blocked Entities.
- General License 127, authorizing through 12:01 a.m. EST, 21 November 2025, certain debt, equity or derivative contracts involving the Blocked Entities.
- General License 128, authorizing through 12:01 a.m. EST, 21 November 2025, certain transactions involving the purchase of goods and services from, or the maintenance, operation, or wind down of Lukoil retail service stations located outside Russia.
- General License 124, authorizing certain petroleum services and other transactions related to the Caspian Pipeline Consortium and Tengizchevroil Projects (superseding previous GL 124).
The following are the Rosneft and Lukoil subsidiaries OFAC designated on the SDN List:
- Limited Liability Company Lukoil Perm.
- Lukoil Aik A Limited Liability Company
- Lukoil Kaliningradmorneft
- Lukoil West Siberia Limited
- Russian Innovation Fuel and Energy Company
- Uraloil
- Aktsionernoe Obshchestvo Kuibyshevskii Neftepererabatyvayushchii Zavod
- AO Sibneftegaz
- Bashneft Dobycha
- CJSC Vankorneft
- JSC East Siberian Oil and Gas Company
- JSC Grozneftegaz
- JSC Rospan International
- JSC Ryazan Oil Refinery Company
- JSC Samaraneftegaz
- Kharampurneftegaz
- LLC Bashneft Polus
- LLC Kynsko Chaselskoe Neftegaz
- LLC RN Purneftegaz
- LLC RN Tuapse Oil Refinery
- LLC RN-Krasnodarneftegaz
- OJSC Achinsk Refinery
- OJSC Novokuybyshevsk Refinery
- OJSC Orenburgneft
- OJSC Samotlorneftegaz
- OJSC Syzran Refinery
- PJSC Verkhnechonskneftegaz
- PJSC Saratov Oil Refinery
- Publichnoe Aktsionernoe Obschestvo Udmurtneft Imeni VI Kudinova
- RN Komsomolskiy Refinery
- RN Nyaganneftegaz
- RN Uvatneftegaz
- RN Yuganskneftegaz
- Taas Yuryakh Neftegazodobycha
This article was authored by Steven Hill, Jeff Orenstein, and Brian Hopkins