OFAC Issues New and Amended Russia-related General Licenses

On November 14, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued several new and amended general licenses authorizing limited transactions under previous sanctions involving Russia’s two largest oil companies, OJSC Rosneft Oil Company and Lukoil OAO.

• Russia-related General License 124B, “Authorizing Petroleum Services and Other Transactions Related to the Caspian Pipeline Consortium, Tengizchevroil, and Karachaganak Projects.” This amended general license authorizes transactions involving these operations in which Rosneft Oil Company and PJSC Oil Company Lukoil are involved.
• Russia-related General License 128A, “Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia.” This amended general license extends until December 13, 2025, all transactions that are ordinarily incident and necessary to the purchase of goods and services from, or the maintenance, operation, or wind down of Lukoil retail service stations located outside of Russia.
• Russia-related General License 130, “Authorizing Transactions Involving Certain Lukoil Entities in Bulgaria.” This new general license authorizes until April 29, 2026, transactions with four Lukoil entities incorporated in Bulgaria, and any entity in which such entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
• Russia-related General License 131, “Authorizing Certain Transactions for the Negotiation of and Entry into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities.”  This new general license authorizes all transactions that are ordinarily incident and necessary to the negotiation of and entry into contracts with PJSC Oil Company Lukoil or any of its affiliates for the sale, disposition, or transfer of Lukoil International GmbH (“LIG”) or any entity in which LIG owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively, “LIG Entities”) through December 13, 2025, provided that the performance of any such contract is made expressly contingent upon the receipt of separate authorization from OFAC.

Certain transactions otherwise prohibited by the Russia Harmful Foreign Activities Sanctions regulations remain unauthorized and, therefore, each of these general licenses requires close analysis.  For additional background information on the sanctions against Rosneft and Lukoil, see Thompson Hine Update of October 23, 2025.  For additional background information on OFAC’s sanctions targeting entities involved in Russia’s oil production, maritime insurers, maritime oil tankers, and other entities engaged in Russia’s energy sector, see Thompson Hine Update of January 15, 2025.