Overview
- OFAC added Rosneft, Lukoil, and numerous subsidiaries to the SDN List on Oct. 22 under Executive Order 14024 targeting Russia’s energy sector.
- U.S. persons must block property and halt dealings with the designated firms, and OFAC’s 50% Rule extends blocking to majority‑owned affiliates.
- General Licenses 126, 127, and 128 authorize limited wind‑down, divestment, and certain non‑Russia Lukoil retail operations through 12:01 a.m. EST on Nov. 21, 2025.
- General License 124A permits specified transactions related to the Caspian Pipeline Consortium and Tengizchevroil projects.
- Legal guidance highlights heightened secondary‑sanctions risk for non‑U.S. institutions facilitating significant transactions, as the UK and EU advance parallel energy measures.