2025.10.22 – US OFAC General License 127 – Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Rosneft or Lukoil

Attached is the license. It allows all transactions that are ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity issued or guaranteed by Rosneft or Lukoil or any of their subsidiaries to a non-U.S. person. The wind-down period expires 12:01 a.m. eastern standard time, November 21, 2025