On 22 October 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated Rosneft Oil Company and Lukoil OAO, along with numerous subsidiaries and affiliates, under Executive Order 14024 for operating in Russia’s energy sector.

This marks another major escalation in US sanctions against Russia’s energy industry. While prior dealings with these companies were permitted in some circumstances under sectoral sanctions, their new SDN status means that:

US companies are now prohibited from all transactions or dealings with Rosneft, Lukoil or any entities 50% or more owned by them; and
Non-US companies may face secondary sanctions if they knowingly engage in significant transactions involving these entities. Secondary sanctions allow OFAC to impose penalties on non-US companies or financial institutions – such as restrictions on access to the US financial system or designation on the SDN List – for supporting or facilitating transactions with sanctioned parties.

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