ARTICLE
31 October 2025

57. October 22, 2025 | Trump Administration Blocks Major Russian Oil Firms

TC
Thompson Coburn LLP

Contributor

For almost 100 years, Thompson Coburn LLP has provided the quality legal services and counsel our clients demand to achieve their most critical business goals. With more than 400 lawyers and 50 practice areas, we serve clients throughout the United States and beyond.
In response to Russia's unprovoked invasion of Ukraine in March 2014 and February 2022, the Department of Treasury implemented various sanctions on Russian entities.
United States International Law
Thompson Coburn LLP are most popular:
  • within Energy and Natural Resources topic(s)
TRUMP ADMINISTRATION TRADE ALERT – SANCTIONS
HEADLINE Trump Administration Blocks Major Russian Oil Firms
DATE October 22, 2025
AGENCY Trump Administration, Department of Treasury
EFFECTIVE DATE October 22, 2025; blocked property must be reported to OFAC within 10 business days
BACKGROUND In response to Russia's unprovoked invasion of Ukraine in March 2014 and February 2022, the Department of Treasury implemented various sanctions on Russian entities. Previously, major Russian oil firms OJSC Rosneft Oil Company and PJSC Oil Company Lukoil had been subject to certain debt-related sectoral sanctions, but not blocking sanctions.
DETAILS OFAC listed Russia's two largest oil companies, Open Joint Stock Company Rosneft Oil Company (Rosneft) and Public Joint-Stock Company Oil Company Lukoil (Lukoil), as Specially Designated Nationals and Blocked Persons (SDNs) pursuant to E.O. 14024.
  • Rosneft is a vertically integrated energy company specializing in the exploration, extraction, production, refining, transport, and sale of petroleum, natural gas, and petroleum products.
  • Lukoilengages in the exploration, production, refining, marketing, and distribution of oil and gas in Russia and internationally.

All property and interests in property of these entities, or any entities they own directly or indirectly >50%, is blocked and must be reported to OFAC within 10 business days of the listing if it is in the United States or in the possession or control of U.S. persons. Additionally, OFAC listed several Russia-based Rosneft and Lukoil subsidiaries, which are reproduced in Annex 1 below. However, any entities owned >50% by Rosneft and Lukoil, even if not explicitly listed by OFAC, are blocked under U.S. law.

Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC's regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons.

OFAC issued wind down and maintenance general licenses associated with these actions.

  • Russia-related General License 124A, "Authorizing Petroleum Services and Other Transactions Related to the Caspian Pipeline Consortium and Tengizchevroil Projects";
  • Russia-related General License 126, "Authorizing the Wind Down of Transactions Involving Rosneft or Lukoil";
  • Russia-related General License 127, "Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Rosneft or Lukoil"; and
  • Russia-related General License 128, "Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia."
  • SDNs may be subject to additional U.S. export restrictions administered by the Department of Commerce, Bureau of Industry and Security (BIS).

BASIS E.O. 14024; IEEPA
Type of Sanction SDN (Blocking); Foreign Financial Institution Secondary Sanctions
COUNTRY All
CITE Designation Announcement: https://ofac.treasury.gov/recent-actions/20251022
Press Release:https://home.treasury.gov/news/press-releases/sb0290


ANNEX 1: ROSNEFT AND LUKOIL SUBSIDIARIES

  • Lukoil subsidiaryLimited Liability Company Lukoil Permis involved in geological exploration and oil and gas production in Russia.
  • Lukoil subsidiary Lukoil Aik A Limited Liability Company is involved in oil and gas production in Russia.
  • Lukoil subsidiary Lukoil Kaliningradmorneft is developing onshore and offshore oil and gas fields in Russia.
  • Lukoil subsidiary Lukoil West Siberia Limited is involved in oil and gas production in Russia.
  • Lukoil subsidiary Russian Innovation Fuel and Energy Company is involved in the development, production, testing, and implementation of new technologies, techniques, and equipment for the development of hard-to-recover hydrocarbon reserves and enhanced oil recovery in Russia.
  • Lukoil subsidiary Uraloil is developing oil and gas fields in Russia.
  • Rosneft subsidiary Aktsionernoe Obshchestvo Kuibyshevskii Neftepererabatyvayushchii Zavod operates an oil refinery in Russia.
  • Rosneft subsidiary AO Sibneftegaz is developing gas and gas condensate fields in Russia.
  • Rosneft subsidiary Bashneft Dobycha is developing almost 200 hydrocarbon fields in Russia.
  • Rosneft subsidiary CJSC Vankorneft is developing a large oil and gas field in Russia.
  • Rosneft subsidiary Joint Stock Company East Siberian Oil and Gas Company is developing an oil and gas condensate field in Russia.
  • Rosneft subsidiary Joint Stock Company Grozneftegaz produces oil and gas in Russia.
  • Rosneft subsidiary Joint Stock Company Rospan Internationalis developing oil and gas deposits in Russia.
  • Rosneft subsidiary Joint Stock Company Ryazan Oil Refinery Company operates an oil refinery in Russia.
  • Rosneft subsidiary Joint Stock Company Samaraneftegaz produces oil in Russia.
  • Rosneft subsidiary Kharampurneftegaz is developing a gas field in Russia.
  • Rosneft subsidiary Limited Liability Company Bashneft Polus explores, produces, and refines oil and oil products in Russia.
  • Rosneft subsidiary Limited Liability Company Kynsko Chaselskoe Neftegaz manages oil and gas condensate fields in Russia.
  • Rosneft subsidiary Limited Liability Company RN Purneftegaz is developing oil and gas fields in Russia.
  • Rosneft subsidiary Limited Liability Company RN Tuapse Oil Refinery operates an oil refinery in Russia.
  • Rosneft subsidiary Limited Liability Company RN-Krasnodarneftegaz produces oil and gas in Russia.
  • Rosneft subsidiary OJSC Achinsk Refinery operates an oil refinery in Russia.
  • Rosneft subsidiary OJSC Novokuybyshevsk Refinery operates an oil refinery in Russia.
  • Rosneft subsidiary OJSC Orenburgneft produces oil and gas in Russia and operates a gas processing plant in Russia.
  • Rosneft subsidiary OJSC Samotlorneftegaz is involved in the exploration and development of oil and gas fields in Russia.
  • Rosneft subsidiary OJSC Syzran Refinery operates an oil refinery in Russia.
  • Rosneft subsidiary PJSC Verkhnechonskneftegaz is developing a large oil and gas condensate field in Russia.
  • Rosneft subsidiary Public Joint Stock Company Saratov Oil Refinery operates an oil refinery in Russia.
  • Rosneft subsidiary Publichnoe Aktsionernoe Obschestvo Udmurtneft Imeni VI Kudinova produces oil in Russia.
  • Rosneft subsidiary RN Komsomolskiy Refinery operates an oil refinery in Russia.
  • Rosneft subsidiary RN Nyaganneftegaz is involved in crude oil production in Russia.
  • Rosneft subsidiary RN Uvatneftegaz is developing almost 40 oil or oil and gas condensate fields in Russia.
  • Rosneft subsidiary RN Yuganskneftegaz produces oil in Russia.
  • Rosneft subsidiary Taas Yuryakh Neftegazodobycha is developing an oil and gas field in Russia.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More