United States: New sanctions intensify pressure on Russia’s oil sector

On October 22, U.S. authorities took a further step in tightening sanctions against Russia’s energy industry. The Office of Foreign Assets Control (OFAC) announced the designation of two major Russian oil companies, Rosneft and Lukoil, under Executive Order 14024, adding them to the SDN List.

As a result, all assets of these companies subject to U.S. jurisdiction are frozen, and any transaction involving U.S. persons or entities is strictly prohibited. In line with the 50 Percent Rule, all subsidiaries owned, directly or indirectly, at least 50 percent by Rosneft or Lukoil are also considered sanctioned, even if not expressly named by OFAC.

To mitigate potential disruptions to certain essential activities, OFAC issued general licenses authorizing limited and narrowly defined transactions. These authorizations remain highly restrictive and require careful legal review to ensure full compliance.

These actions form part of a broader Western effort to tighten sanctions on Russia’s energy revenues, with tangible economic effects already emerging across international energy markets and global supply chains.

For companies operating internationally, this development underscores the importance of continuous sanctions screening, ownership analysis, and robust export compliance frameworks to prevent inadvertent violations in an increasingly complex regulatory environment.