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.

Posted in OFAC, Russia, Ukraine, Ukraine-Russia Crisis
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Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

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Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

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Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.

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Photo of Kristina Shcheglazova* Kristina Shcheglazova*

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control…

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control matters, including compliance with various sanctions and export control requirements, due diligence and sanctions screenings, and advises clients on the application of U.S. sanctions and export control licensing requirements. Her experience extends to addressing issues of forced labor in supply chains, assisting clients with government contracting matters and advising on anti-corruption policies.

*Licensed in MO only, not IL; limited to federal practice only.

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