On 15 October 2025, the UK introduced new designations targeting the Russian energy sector. Among the designated organisations are Russia‘s largest oil producers, PJSC Rosneft Oil Company, PJSC Oil Company Lukoil and Nayara Energy Limited. The list of newly designated entities involved in supporting the Russian energy sector also includes 4 oil terminals in China. The UK has issued a general licence authorising wind-down activities in relation to Rosneft and Lukoil until November 28, 2025. A supplementary general licence provides an exemption for working with Lukoil and Rosneft subsidiaries on certain “exempt projects”.
Targeting the Russian shadow fleet during July and September 2025, the UK designated over 50 vessels involved in the transportation of Russian LNG and oil on 15 October.
The US added PJSC Rosneft Oil Company and PJSC Oil Company Lukoil to the SDN list on 22 October 2025. There is a limited wind-down licence in place until 21 November 2025.
The repercussions of this designation have included Lukoil announcing an intention to dispose of its non-Russian assets.
The EU adopted the 18th (on 18 July 2025) and 19th (on 23 October 2025) Russia sanctions packages. The packages expanded the list of designated individuals and vessels, added new CN Codes to the lists of goods subject to trade sanctions and introduced various additional sanction measures. The 18th package included a complete ban on all transactions related to the Nord Stream 1 and 2 pipelines (with some limited exceptions) and set a new rule (starting from 21 January 2026) that prevents buying, importing, or transferring refined petroleum products into the EU from other countries if they are made from Russian crude oil.
The key new sanctions measures introduced by the 19th package include:
- The 19th package prohibits the direct or indirect purchase, import, or transfer of LNG originating or exported from Russia into the EU, along with any related technical or financial assistance. The new prohibitions will enter into force from 25 April 2026 (i.e., a nine-month transition period) or from 1 January 2027 for purchases/imports/transfers done under contracts of over 1 year concluded before 17 June 2025. The Article 5aa(3a) and (3aa) exemptions related to purchasing/importing natural gas and oil/oil products from Russia also do not apply any longer.
- There is a prohibition on providing insurance and reinsurance for used vessels and aircraft that were operated by the government of Russia or a Russian company for five years after their sale or lease.
- Ports and locks outside Russia can now be placed under a transaction ban because they have been involved in transferring UAVs or circumventing the oil price cap. No ports/locks have been added to this new list yet (new Annexure XLVII Part C).
- The ban prohibits any new participation in, the creation of joint ventures with, and the provision of financing to any enterprise established in or operating through certain special economic, innovation, or preferential zones, as well as entering into new contracts with such enterprises. The 11 affected zones are listed in a new Annexure LII.
- 5 additional Russian financial institutions have been made subject to the Article 5h transaction ban, including JSC “ALFA-BANK” and PJSC “MTS Bank” (the prohibition on the new financial institutions entered into force on 12 November 2025).
- 4 non-Russian banks have also been added to the Annexure XLIV list of entities affected by the Article 5ac(2) transaction ban because they use Russian financial messaging services. These all appear to be overseas entities of Russian banks, e.g., VTB Kazakhstan.
- A new ban on connecting EU entities to additional Russian financial messaging systems (“Mir” and “Fast Payment System”/”SBP”) comes into effect on 25 January 2026.
