On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the immediate imposition of full blocking sanctions pursuant to Executive Order (“E.O.”) 14024 against Russian oil companies PJSC Lukoil Oil Company (“Lukoil”) and PJSC Rosneft Oil Company (“Rosneft”), along with over two dozen of their subsidiaries, for operating



