On 15 October 2025, the UK imposed further sanctions targeting Russian energy sector. The most noteworthy element was the designation of two largest Russian oil companies, Rosneft and Lukoil. These two designations follow on earlier designations of Gazprom Neft and Surgutneftegas (made in January 2025) which are the next largest Russian producers of crude. The designations apply to such oil majors as well as any person owned or controlled by them. The general license permitting to wind-down relationships with Rosneft, Lukoil, and their owned or controlled persons is available here.
Amendments were made to an existing general licence to allow the UK persons to purchase petrol products from Rosneft and Lukoil subsidiaries in Tajikistan and Kyrgyzstan as well as to a licence permitting to process payments for the period until 28 June 2026 for Sakhalin-2 and until 14 October 2027 for CPC, TengizChevroil, Shah Deniz, the South Caucasus Pipeline, The Azerbaijan Gas Supply Company and Karachaganak.
A noteworthy element of these sanctions was the designation of prominent non-Russian entities for their dealing in Russian crude and LNG, namely: four oil terminals in China and an oil refinery operator in India, Nayara Energy Limited, – which imported 100 million barrels of Russian crude worth over $5 billion in 2024, as well as the Chinese Beihai LNG terminal which was importing LNG from Arctic LNG2. The relevant wind-down licence was also issued for terminating transactions with these designated persons and is available here.
Further designations related to 44 tankers in the “shadow fleet” transporting Russian oil and eight specialised LNG tankers.
The full list of the entities and vessels designated today is available here.
We discussed the current sanctions regimes relevant for the Russian energy sector in our video related to Russian crude and petroleum products, the video related to trade in Russian natural and LNG gas as well as in our video where we discussed sanctions against Russian “shadow fleet”.
