On October 15, 2025, the UK announced a significant expansion of its Russia-related sanctions regime, designating Lukoil and Rosneft—Russia’s two largest oil companies—as asset freeze targets.

This is the first time Lukoil and Rosneft have been subjected to full asset freezing sanctions by any of the UK, U.S., or EU, and follows earlier UK measures against Gazprom Neft and Surgutneftegas in January 2025, Russia’s third and fourth largest oil companies. By targeting the parent companies, the UK sanctions will also extend to any companies that Lukoil or Rosneft majority own or otherwise control.

The new package also notably sanctions:

  • Nayara Energy Limited (an Indian refinery, 49% owned by Rosneft). This follows the EU’s sanctions on Nayara in July.  In contrast to the EU’s action against Nayara, the UK issued a wind-down license for Nayara and the Chinese energy companies mentioned below), which expires on November 13, 2025;
  • an UAE commodity trading house (Wissol Commodities), several Chinese oil refineries and the Beihai LNG terminal (which had been importing LNG from the sanctioned Arctic LNG 2 project);
  • an additional five Russian banks; and
  • companies that have been supplying electronics critical for Russian drones and missiles, including companies based in Thailand, Singapore, Turkey and China.

The UK has continued its focus on vessels by specifying an additional 51 ships, including 44 identified as part of the “shadow fleet” used to transport Russian oil. These vessels are now prohibited from accessing UK ports and have any UK registration revoked.

In parallel, the UK issued a wind-down licence for transactions involving Rosneft, Lukoil and their subsidiaries (which expires on November 28, 2025) and amended two existing licences to allow transactions with Lukoil and Rosneft to continue in relation to 6 specified oil projects and to allow petrol station payments in Kyrgyzstan and Tajikistan.

The UK has also announced that it will introduce a ban on the import of oil products refined in third countries from Russian-origin crude, aiming to address indirect flows of Russian oil into global markets. This will require amending regulations to be passed and follows the EU’s similar announced prohibition which comes into effect on 21 January 2026. Overall, these developments represent a notable escalation in UK sanctions on Russia and its oil revenues, especially by sanctioning Lukoil and Rosneft, energy companies that remain integrated into global markets and with operations and activity today in countries allied with the UK.  It remains to be seen whether the EU will follow suit and target Lukoil and Rosneft as part of its 19th sanctions package, which is due imminently and similarly expected to focus on placing continuing pressure on Russian energy.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Dj Wolff Dj Wolff

David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with Crowell Global Advisors, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice

David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with Crowell Global Advisors, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice focuses on all aspects of compliance with U.S. economic sanctions, including day-to-day compliance guidance, developing compliance programs, responding to government inquiries, conducting internal investigations, and representation during civil and criminal enforcement proceedings. Dj works regularly with non-U.S. clients, both in Europe and Asia, to evaluate the jurisdictional reach of U.S. sanction authorities to their global operations, identify and manage the potential conflict of laws that can result from that reach, as well as to support client’s design, implementation, and evaluation of a corresponding risk-based sanctions compliance program. Dj also regularly leads teams in diligence efforts on trade and related regulatory areas on behalf of his U.S. and non-U.S. clients in the M&A arena, having successfully closed more than 30 deals with an aggregate valuation of several billion dollars over the last 18 months.

Dj is ranked by Chambers USA in International Trade: Export Controls & Economic Sanctions. He has previously been recognized by Law360 as a Rising Star in International Trade (2020), by The National Law Journal as a “DC Rising Star” (2019), by Who’s Who Legal: Investigations as a “Future Leader” (2018 and 2019), Acritas Star as an Acritas Stars Independently Rated Lawyers (2019), by Global Investigations Review as one of the “40 under 40” in Investigations internationally (2017), and WorldECR as one of the five finalists for the WorldECR Young Practitioner of the Year award (2016).

Photo of Sophie Davis Sophie Davis

Sophie Davis is an associate in Crowell’s London office and advises clients on a range of sanctions, export controls, and trade compliance matters. Sophie has particular experience advising multinational corporations and financial institutions on how to comply with rapidly evolving trade and financial

Sophie Davis is an associate in Crowell’s London office and advises clients on a range of sanctions, export controls, and trade compliance matters. Sophie has particular experience advising multinational corporations and financial institutions on how to comply with rapidly evolving trade and financial sanctions across a range of EU and UK sanctions regimes, assisting corporate clients with complex sanctions issues arising from their continued operations in, or divestments from, Russia, and supporting clients with licensing applications and responding to investigations.

Sophie also assists companies on compliance with anti-bribery and anti-money laundering laws, foreign direct investment requirements, human rights, environmental and sustainability regulatory requirements. Prior to joining Crowell & Moring, Sophie worked in the international trade and regulatory team in another top international law firm, based in London, as well as for a leading New Zealand law firm.

Photo of Andrew J. Schlegel Andrew J. Schlegel

Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border

Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection (CBP). He works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. Andrew also supports unfair trade investigations, including antidumping (AD) and countervailing duty (CVD) investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission (ITC).

Prior to joining Crowell & Moring, Andrew worked as an intern at SAP’s Government Affairs Business Development Team in Berlin, Germany. There, he analyzed the effects of regulatory changes on SAP business operations and expansion opportunities. Before this, he completed an internship at the International Trade Administration’s Office of Energy and Environmental Industries. While there, he developed the U.S. Energy Trade Dashboard, an interactive data visualization tool for use by professionals and researchers to analyze how energy supply chains have developed.