In “US Treasury Issues Sanctions Waivers for Certain Lukoil Sales” (Energy Intelligence, 14 November 2025), Amir Fadavi comments on the issuance by the U.S. Treasury of sanctions waivers allowing limited transactions and negotiations involving Lukoil’s international assets until December 13. The new licenses and waivers—which come a week before the 21 November expiration of the wind-down period before U.S. sanctions on Lukoil and Rosneft take effect—raise questions for international oil companies (IOCs) partnering with Lukoil or Rosneft. Amir notes: “For IOCs with interests in upstream assets in which Lukoil or Rosneft holds a majority stake, the entity that operates the upstream is sanctioned. Consequently, any other company dealing with that entity or oil extracted by such an entity risks being hit by ‘secondary sanctions.’”
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