Sanctions Watch | Weekly Vol. 124

Sanctions Watch Vol 124

In the latest edition of our Sanctions Watch weekly digest, we present significant updates on sanction watchlists and regulatory developments.

EU Adopts 19th Sanctions Package Against Russia, Targeting Energy, Finance, and Military Sectors

The European Union has adopted its 19th package of sanctions against Russia, marking one of the bloc’s most comprehensive efforts to curb the Kremlin’s war economy. The new measures, approved during the Foreign Affairs Council (Defence) roundtable, aim to intensify economic pressure by targeting key sectors including energy, finance, trade, and technology, as well as individuals and entities enabling Russia’s aggression against Ukraine.

At the core of the package is a total ban on Russian liquefied natural gas (LNG)—effective from January 2027 for long-term contracts and within six months for short-term ones—alongside an expanded crackdown on Russia’s “shadow fleet.” The EU also imposed full transaction bans on energy giants Rosneft and Gazprom Neft, sanctioned Chinese and UAE entities facilitating Russian oil exports, and listed 117 additional vessels, bringing the total to 557.

Financially, the sanctions blacklist five Russian banks, restrict access to Mir and SPFS payment systems, and— for the first time—extend to cryptocurrency platforms and stablecoins involved in sanctions evasion. Trade restrictions expand to include dual-use technologies, metals, salts, and rubber goods worth over €155 million.

The EU also introduced anti-circumvention tools, blacklisting 45 additional entities from Russia, China, India, and Thailand, and implemented bans on Special Economic Zones, AI, space-based services, and re-insurance.

This decisive package reinforces the EU’s determination to undermine Russia’s financial and industrial resilience, close loopholes, and uphold accountability for violations tied to the ongoing war in Ukraine.

UK Grants General Licence Allowing Contin

The UK Treasury’s Office of Financial Sanctions Implementation (OFSI) has issued a General Licence (INT/2025/7598960) permitting the continued operation of PJSC Rosneft Oil Company’s German subsidiaries — Rosneft Deutschland GmbH and RN Refining & Marketing GmbH — despite ongoing sanctions under the Russia (Sanctions) (EU Exit) Regulations 2019.

This licence, effective from 22 October 2025 to 22 October 2027, allows entities and individuals to continue business activities with these subsidiaries, including making and receiving payments, fulfilling existing and new contractual obligations, and providing or receiving economic resources. It also authorizes UK financial institutions to process such payments, ensuring continuity of financial and operational transactions necessary for the subsidiaries’ business functions. The authorization allows individuals, organizations, and Relevant UK Institutions—such as banks, clearing houses, and payment service providers—to complete activities necessary for the closure of positions or disengagement from ongoing transactions with the DPs. The licence is valid from 15 October 2025 until 13 November 2025.

However, the licence explicitly states that it does not permit any action breaching other provisions of the Russia Sanctions Regulations unless covered by this or other specific licences. The measure reflects a pragmatic approach to maintaining Germany’s fuel and energy infrastructure, while ensuring compliance with broader UK sanctions policy.

OFSI reserves the right to revoke, vary, or suspend the licence at any time. Information related to its use is subject to data protection regulations under the UK GDPR and Data Protection Act 2018.

U.S. Treasury Issues General License 124A Authorising Petroleum Services Linked to Caspian Pipeline and Tengizchevroil Projects

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued General License No. 124A under the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587). Effective October 22, 2025, this license replaces and supersedes the earlier General License No. 124 issued on May 15, 2025.

The new authorization permits certain transactions and petroleum-related services otherwise prohibited under the sanction’s determination of January 10, 2025, pursuant to Executive Order 14071, titled “Prohibition on Petroleum Services.” Specifically, it allows U.S. and allied entities to conduct transactions connected to the Caspian Pipeline Consortium and Tengizchevroil projects—two critical operations for global energy markets and regional stability.

Furthermore, the license authorizes dealings involving specific Russian energy majors, including Rosneft Oil Company and Lukoil, as well as entities where either company holds a direct or indirect ownership stake of 50% or more.

However, the authorization excludes any transactions involving persons blocked under the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR) not explicitly listed in this license.

OFAC, reaffirming the Treasury’s approach of balancing sanctions enforcement with the need to maintain critical energy operations tied to multinational ventures.

This update underscores Washington’s ongoing effort to refine its sanctions framework while ensuring continued support for key petroleum infrastructure in the Caspian region.

UK Issues New Legal Services General Licence INT/2025/7323088 under Sanctions Act 2018

The UK Office of Financial Sanctions Implementation (OFSI) has issued a new Legal Services General Licence (INT/2025/7323088) under the Sanctions and Anti-Money Laundering Act 2018. This licence, effective 29 October 2025 to 28 April 2026, replaces the previous licence INT/2024/6160920 and expands its coverage across most UK Autonomous Sanctions Regimes listed in Annex 1.

Under this General Licence, UK-based law firms, counsel, and providers of related expenses can receive payments from designated persons (DPs) for legal services rendered, without requiring a specific OFSI licence—provided they comply fully with the terms of INT/2025/7323088.

The licence excludes payments made directly or indirectly to any person designated under United Nations obligations. It also emphasises that no permissions extend to activities that might breach the UK Autonomous Sanctions Regimes unless explicitly authorised. Licensees must submit payment reports to HM Treasury within 14 days using the online form specified in the licence, and maintain accurate records for six years. The OFSI reserves the right to vary, revoke, or suspend the licence at any time.

This update aims to streamline compliance for legal professionals while maintaining strict oversight under the UK’s sanctions framework.

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Sanctions Watch is a weekly recap of events and news related to sanctions around the world.