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US, UK and EU Roll Out Toughest Russia Sanctions to Date, Hitting Energy Giants and Shadow Fleet

The coordinated packages expand penalties to actors outside sanctions jurisdictions via secondary‑sanctions exposure, pushing global finance and energy firms to tighten compliance.

Overview

  • OFAC on October 22 named Rosneft, Lukoil and 34 subsidiaries as SDNs under E.O. 14024, imposing full blocking sanctions and issuing time‑limited general licenses, including wind‑down authorizations through November 21 for transactions and certain Lukoil retail operations outside Russia.
  • EU leaders on October 23 adopted a 19th sanctions package that imposes a full transaction ban on Rosneft and Gazprom Neft and schedules LNG and LPG import bans for April 2026 on short‑term deals and January 1, 2027 on long‑term contracts.
  • The EU package also targets five Russian banks and five banks in Central Asia, adds shadow‑fleet vessel measures, tightens service and trade restrictions, and for the first time bans transactions in the A7A5 stablecoin.
  • The UK on October 15 sanctioned Rosneft and Lukoil, listed 51 shadow‑fleet vessels with related transport prohibitions, set wind‑down licenses through November 28, and issued a separate license allowing two German Rosneft subsidiaries under trusteeship to continue operations.
  • Treasury framed the US action as a response to Russia’s lack of serious engagement in a peace process, while regulators and analysts warn the combined steps markedly raise global compliance risk for banks, traders and refiners.