U.S. Imposes Full Blocking Sanctions on Rosneft and Lukoil Under E.O. 14024

Overview

• OFAC designated Rosneft and Lukoil as Specially Designated Nationals and listed numerous Russia‑based subsidiaries, extending blocking to any entities they own 50 percent or more.
• All property and interests in property of the named parties under U.S. jurisdiction are blocked, and U.S. persons are generally barred from transactions with them.
• Treasury issued General Licenses 124A, 126, 127 and 128 authorizing specified petroleum services, wind‑down activities, divestments of debt or equity and certain dealings with Lukoil retail stations outside Russia through November 21, 2025.
• OFAC cautioned foreign financial institutions that facilitating significant transactions for the designated parties could trigger secondary sanctions, including restrictions on U.S. correspondent or payable‑through accounts.
• The UK’s OFSI issued a time‑limited general licence permitting continued operations with named Rosneft subsidiaries and added guidance addressing business with German subsidiaries.