On 22 October 2025, the US OFAC designated Russia’s two largest oil companies, Rosneft and Lukoil, to its SDN list. The designations were made under E.O. 14024 for operating or having operated in the energy sector of the Russian Federation economy.
Further, certain Rosneft’s and Lukoil’s subsidiaries were listed SDNs by name. This means that US sanctions will continue to apply to such companies even if they are sold to non-sanctioned buyers and their de-listing will require the express decision of OFAC.
In addition, even if a subsidiary of Rosneft or Lukoil is not designated by name, it is subject to the same sanctions as its ultimate parent company, because US sanctions apply to any entity in which one or more of the SDNs own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
These designations follow the listing to asset-freeze sanctions of the same companies by the UK which we discussed earlier.
Four general licenses (“GLs“) were issued by OFAC together with these SDN listings. The GLs are: (1) GL 124A which authorises transactions with respect to Caspian Pipeline Consortium or Tengizchevroil projects; (2) GL 126 which sets out a standard wind-down period expiring on 21 November 2025; (3) GL 127 which permits divestment of debt and equity securities issued or guaranteed by any designated entity until 21 November 2025; and (4) GL 128 which permits transactions with Lukoil Retail Service Stations until 21 November 2025. Notably, unlike a typical OFAC wind-down general license, GL 128 allows payments to be made to Lukoil Retail Service Stations (rather than to a blocked account) in connection with any such a transaction.
Further, on 29 October 2025, US OFAC issued license no. 129 which authorises transactions with Rosneft Deutschland GmbH or RN Refining & Marketing GmbH, which operate three large refineries in Germany critical for petroleum supply in Germany. The license expires on 29 April 2026.
This is, certainly, one of the most important set of sanctions introduced by the US OFAC so far with respect to the Russian oil sector which is a key source of Russia’s export revenues.
For other sanctions affecting the Russian oil sector please see our video on sanctions relevant for trade in Russian crude and petroleum products (link to the video), a video with respect to sanctions targeting Russian “shadow fleet” (link to the video), as well as the video discussing sanctions affecting Russian pipeline natural gas and LNG (link to the video).
We also considered earlier other sanctions taken by the Trump’s Administration with respect to Russian oil exports in our video related to tariffs imposed by the US against India in response to India’s continuing purchases of Russian crude (link to the video).