US sanctions major Russian oil companies

23 October 2025

US sanctions major Russian oil companiesBillion Photos/Shutterstock.com

The US has designated Rosneft and Lukoil, two of Russia's largest oil companies, under the US’ Russian harmful foreign activities sanctions regime, EO 14024press release.

Designations

Open Joint Stock Company Rosneft Oil Company and Lukoil OAO have been designated under EO 14024 for “operating in the energy sector of the Russian Federation”. The US Treasury said:

  • Rosneft is a vertically integrated energy company specializing in the exploration, extraction, production, refining, transport, and sale of petroleum, natural gas, and petroleum products.
  • Lukoil engages in the exploration, production, refining, marketing, and distribution of oil and gas in Russia and internationally.

34 Rosneft and Lukoil’s subsidiaries have also been designated, also for operating in Russia’s energy sector. These include Russia-based oil refineries and companies linked to the production and distribution of oil and gas in Russia. All entities owned 50 percent or more, directly or indirectly, by Rosneft and Lukoil are also blocked under EO 14024, even if not designated by the US Office of Foreign Assets Control (OFAC) – information on the US’ 50% rule is on our US Guidance page.

The US directly linked these designations to the war in Ukraine. Treasury Secretary Scott Bessent said the US is also prepared to take further action if necessary to stop the war in Ukraine. Rosneft and Lukoil were sanctioned by the UK on 15 October 2025.

Licences

OFAC issued 4 general licences related to the Rosneft and Lukoil designations:

  • GL 124A authorises petroleum services and other related transactions to the Caspian Pipeline Consortium and Tengizchevroil Projects. It replaces GL 124 (15 May 2025).
  • GL 126 authorises the wind down of transactions involving Rosneft or Lukoil. The licence expires at 12.01am (Washington DC time) on 21 November 2025.
  • GL 127 authorises certain transactions related to debt or equity of, or derivative contracts involving Rosneft or Lukoil. The licence covers transactions entered into before 22 October 2025 and extends until 12.01am on 21 November 2025.
  • GL 128 authorises certain transactions involving Lukoil retail service stations outside of Russia until 12.01am on 21 November 2025. Lukoil retail service stations mean physical retail service stations located outside the Russian Federation and in existence on or before 22 October 2025 in which Lukoil has an interest or any entity in which Lukoil owns, directly or indirectly, a 50% or greater interest, has an interest. (According to Lukoil North America, Lukoil operates over 200 stations in the US.)

All US GLs are on our US Licensing page.

Implications

As a result of these designations:

  • All of Rosneft and Lukoil’s property and property interests in the US blocked and must be reported to OFAC. Any entity owned 50% or more, directly or indirectly, by Rosneft, Lukoil, or one of the designated subsidiaries, is also blocked. Information on when property is blocked in the US is available on our US Guidance page.
  • All transactions by people or entities in or transiting within the US that involve any Rosneft or Lukoil property or property interests are prohibited unless they fall within one of the 4 GLs.
  • Non-US people or entities who conduct or facilitate significant transactions with Rosneft, Lukoil or their subsidiaries may risk secondary sanctions – sanctions which can be imposed on foreign people or institutions for knowingly conducting or facilitating significant transactions with designated parties, even if those individuals or institutions are outside the US.

See our US pages and our US Russia regime page for more information about US sanctions and enforcement.

Maya Lester KC

Maya Lester KC is a senior barrister (King’s Counsel) at Brick Court Chambers with a wide-ranging practice in public law, European law, competition law, international law, human rights & civil liberties. She has a particular expertise in sanctions. She is the…

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