A Guide to US, UK and EU Sanctions and Export Controls on Russia and Belarus
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Key Takeaways:
- Since Russia’s February 24, 2022, invasion of Ukraine, the United States, the United Kingdom and the European Union, along with other countries, have imposed extensive sanctions and export controls on Russia, Belarus and the Russian-occupied regions of Ukraine.
- On October 22, 2025, the Trump Administration took its first major action targeting Russia with the sanctions designation of Open Joint Stock Company Rosneft Oil Company (“Rosneft”), Public Joint-Stock Company Oil Company Lukoil (“Lukoil”) and various Russia-based Rosneft and Lukoil subsidiaries. The United States framed the step as a response to Russian President Vladimir Putin’s refusal to end the war and signaled the possibility of further action if necessary to support President Donald Trump’s effort to end the war.
- In connection with these measures, OFAC issued several general licenses, including, among others: licenses authorizing transactions with Rosneft and Lukoil entities related to the operation of the Caspian Pipeline Consortium, Tengizchevroil or Karachaganak projects; wind down transactions involving Rosneft or Lukoil entities; transactions to divest debt or equity of, or wind down derivative contracts involving, Rosneft or Lukoil entities; and certain transactions for the negotiation of and entry into contingent contracts for the sale of Lukoil International GmbH.
- UK and EU sanctions and export control measures continue to expand with the purpose of eroding Russia’s ability to support the war.
- This Guide provides an overview of the myriad sanctions and export controls adopted by these jurisdictions, the general licenses issued in connection with these measures and additional guidance published as of of 9:00 a.m. EDT November 20, 2025.