The UK and US have announced sanctions against major Russian oil companies Gazprom Neft and PJSC Surgutneftegas, and published two related General Licences. The UK's Office of Financial Sanctions Implementation (OFSI) and the US Office of Foreign Assets Control (OFAC) recently signed a Memorandum of Understanding (MOU) which aims to improve information sharing and cooperation between the agencies on sanctions enforcement. Finally, OFSI has issued a new General Licence addressing basic necessities for designated persons.
New UK and US Sanctions on Russian Oil Companies
On 10 January 2025 the UK, simultaneously with the US, announced new sanctions targeting Gazprom Neft and PJSC Surgutneftegas. These major Russian energy companies collectively produce over 1 million barrels of oil per day. The sanctions are part of the UK's broader initiative to curtail Russia's ability to generate revenues from energy sales, thereby weakening the financial resources supporting its military activities in Ukraine. Gazprom Neft is therefore subject to both an asset freeze and the pre-existing investment ban.
OFSI has also issued two new General Licences in relation to the above designations. The first licence provides a wind-down period until 27 February 2025 for businesses to cease working with Gazprom Neft and PJSC Surgutneftegas. The second licence permits businesses to continue operations related to the Sakhalin-2 project until 28 June 2025, with the aim of ensuring minimal disruption to specific essential energy projects.
OFAC-OFSI Memorandum of Understanding
On 13 January 2025 OFSI announced it had recently signed a Memorandum of Understanding (MOU) with OFAC as part of their ongoing "enhanced partnership". This MOU states the US and UK agencies' intentions to increase their collaboration, including by sharing relevant information, coordinating on investigations and enforcement, discussing regulatory expectations and undertaking training and secondments. The MOU covers information requests, related controls and safeguards, record keeping and coordination.
General Licences on Interim Basic Necessities for Designated Persons
OFSI has also issued a new General Licence covering interim basic necessities for designated persons. The licence allows designated UK persons to access funds up to a permitted maximum of £350 per month for basic necessities, including food, medicines, and household products, for the two months following their designation. It applies across all UK autonomous sanctions regimes, as listed in Annex 1 to the general licence.
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