Sanctions Watch | Weekly Vol. 131

Sanctions Watch Vol 131

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

1. OFAC Issues Amended General License No. 131A for Lukoil Sale and Maintenance Activities Amid Sanctions

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 131A, an amended license that authorizes certain transactions with Russian oil giant Lukoil International GmbH (LIG) and its affiliates. This license allows for the negotiation and entry into contingent contracts related to the sale, disposition, or transfer of LIG or any entity in which LIG holds a 50% or more stake, through January 17, 2026. It also covers maintenance or wind-down activities for LIG Entities.

The general license, however, maintains several key restrictions, notably excluding the unblocking of any property blocked under the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR), or transactions involving blocked persons not specified in the license. Additionally, the transfer of funds to individuals or entities located in the Russian Federation remains prohibited.

This amendment supersedes the previous General License No. 131, which was issued in November 2025. The move is seen as a critical step in facilitating the negotiation process for transactions involving Lukoil while ensuring compliance with ongoing sanctions imposed on Russia in light of its harmful foreign activities.

2. EU Extends Sanctions on 31 Individuals and 2 Entities in the Democratic Republic of the Congo Over Human Rights Violations and Armed Conflict

The European Union announced the extension of its restrictive measures on 31 individuals and two entities linked to human rights abuses, electoral obstruction, and the ongoing armed conflict in the Democratic Republic of the Congo (DRC). These sanctions, now extended until 12 December 2026, include asset freezes and a travel ban preventing the designated persons from entering or transiting through EU member states. These actions are in response to persistent instability, insecurity, and violence in the DRC, further exacerbated by the illicit exploitation of natural resources.

The EU’s restrictive measures were first introduced in 2016, targeting individuals responsible for severe human rights violations and interference in the electoral process. In December 2022, the criteria for designations were expanded to include those who sustain or benefit from the ongoing conflict, or exploit the country’s resources amidst its instability. The EU continues to monitor the situation closely and retains the flexibility to amend or renew these sanctions based on evolving developments. The current sanctions complement the United Nations’ existing measures, reinforcing international efforts to address the ongoing crisis in the DRC.

3. OFSI Extends and Amends General Licence for Russian Travel, Allowing Ticket Purchases from JSC Siberia

The Office of Financial Sanctions Implementation (OFSI) in the UK amended General Licence INT/2022/1839676, which regulates the purchase of tickets from Russian transport providers. The updated licence now permits UK individuals and institutions to purchase tickets from JSC Siberia Airlines (S7 Airlines), expanding its scope. Previously, the licence allowed UK persons to purchase tickets from certain Russian airlines and railway companies, subject to specific conditions. The amendment also extends the validity of the licence until May 22, 2028.

The General Licence, originally granted in May 2022 under the Russia (Sanctions) (EU Exit) Regulations 2019, exempts UK nationals from sanctions prohibiting transactions related to passenger rail and air journeys within Russia and between Armenia and Georgia. However, the licence remains subject to strict conditions, ensuring that no funds or economic resources breach the Russia Regulations. The continued extension and amendment of this licence reflect ongoing considerations of the political and economic environment in Russia, with OFSI retaining the authority to modify or revoke the licence at any time

4. Australia Implements New Sanctions Framework Against Haiti Amid Gang Violence and Instability

The Australian Government established a new sanctions framework related to Haiti, aligned with the United Nations Security Council (UNSC) sanctions. These measures, first imposed in 2022 due to escalating gang violence and criminal activities threatening Haiti’s peace and stability, are now incorporated into Australian law through the Charter of the United Nations (Sanctions – Haiti) Regulations 2025.

The regulations impose various restrictions, including bans on the supply of arms and related materials, restrictions on assets related to designated persons or entities, and travel bans on individuals linked to these activities. The Australian Department of Foreign Affairs and Trade (DFAT) has added 9 individuals and 2 entities to its Consolidated List. These include figures such as Jimmy Cherizier, Johnson Andre, and entities like Gran Grif and Viv Snsanm.

The designations prevent listed persons from traveling to or remaining in Australia, and it is an offense to deal with their assets without Ministerial authorization. The framework also outlines a process for requesting permits to deal with “controlled assets” under specific conditions. This legal action aims to support global efforts to restore peace and stability in Haiti.

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