UK General Licence for Lukoil International Business Continuation
Summary
The UK Treasury has issued a general licence allowing certain business operations involving Lukoil International and its subsidiaries to continue, despite existing sanctions. This licence is effective from November 27, 2025, and expires on February 26, 2026.
What changed
This general licence, issued under the Russia (Sanctions) (EU Exit) Regulations 2019, permits persons to continue business operations with Lukoil International and its subsidiaries. This includes making and receiving payments and providing economic resources, subject to conditions. Funds that would otherwise be due to Lukoil International or its subsidiaries must not be made available to them unless paid into a frozen account or until they are no longer controlled by PJSC Lukoil. Relevant UK financial institutions may process these payments.
Regulated entities, particularly those in the financial services sector, must review the licence conditions carefully to ensure compliance. The licence provides a limited window for continued business, expiring on February 26, 2026. Failure to adhere to the specific permissions and conditions could result in breaches of sanctions regulations.
What to do next
- Review the general licence terms and conditions for Lukoil International business.
- Ensure all payments and economic resource provisions comply with licence restrictions, particularly regarding frozen accounts.
- Note the licence expiry date of February 26, 2026, and plan accordingly for post-expiry operations.
Penalties
Breach of the Russia Regulations may result in penalties, though specific penalties are not detailed in this licence.
Source document (simplified)
GENERAL LICENC E – Continuation of Business of Lukoil International En tities INT/2025/8031092 1. This licence is granted unde r regulation 64 of the Rus sia (Sanctions) (E U Exit) R egulations 2019 (“the Russia Regulatio ns”). 2. Any act which w ould other wise breach the prohibitions in Regulation s 11 to 17 and 18C of the Russia Regulations is exempt from those prohibit ions to the extent required to give effect to the permissions in this licen ce. 3. In this licence: “Lukoil International ” means Lukoil International GmbH which is a subsidiar y of PJSC Lukoil. a “Lukoil Internati onal Subsidiary ” means Any e ntity owned or controlled, directly or indirectly, by Lukoil International withi n the mea ning of regulat ion 7 of the Russia Regulations. a “ Person ” means An individual, a body o f persons corporat e or unincorpo rate, any organisation or any a ssociation or combination o f persons which is not itself a UK DP. a “UK DP” means Any individual or a bod y of persons (corporate or unincorporate) designat ed under regulation 5 of t he Russia Regulations and/or any i ndividual or body o f persons (corporate or unincorpora te) owned or c ontrolled direct ly or indirectly by that desig nated person within the mea ning of regulation 7 of the Russ ia Regulat ions other than Lukoi l International a “ Relevant UK Ins titution ” means A person that has permi ssion under Part 4A o f the Financial Services and Markets A ct 2000 (permissio n to carry on regulated activity). A person that is authorised or registered under Pa rt 2 of the Payment Services Regulat ions (SI 2017/75 2). A person that is authorised or registered under Pa rt 2 of the Electronic Money Regulat ions (SI 2011/ 99). A person that is a “recog nised clearing house”, “third country central counterparty ”, “recognised CSD” or “third country CS D” for the purposes of s.285 of the Financial Servi ces and Markets Act 2000. A person that is an opera tor of a recognised pa yment system (or that is a service provide r in relation to re cognised payme nt systems) for the purpose s of Part 5 of the Ban king Act 2009.
Permissions 4. Under this licence, subje ct to the condition s below: 4.1. A Person may continue business operations involving Lukoil International and a Lukoil International Subsidiar y including, but not lim ited to: 4.1.1. Payments to or from Lukoil International and/ or a L ukoil International Subs idiary under any existing or new obliga tions or contracts; 4.1.2. Payments to or from an y other Person under an y obligations or contracts; and 4.1.3. Provision of, a nd receipt of, economic re sources from Lukoil International a nd/ or a Lukoil International Subsidi ary. 4.2. Insofar as Luk oil International or a Lukoil Internationa l Subsidiary would have been (but for their designat ion) e ntitled t o any funds (or any legal or equitable interests or righ ts there in) under paragraph 4.1 funds must not be made available (e ither dire ctly or indirectly) t o, or for the benefit of L ukoil International or a Lukoil Internati onal Subsidiary unless such funds are paid into a froze n account or until such time as Lukoil International is no longe r owned or controlled, dire ctly or indire ctly, by PJSC Lukoil within the meaning of regulation 7 of the R ussia Regulations. 4.3. Subject to paragraph 4.2 above, Relevant UK Instit ution may proces s payme nts made in accordance with paragra phs 4.1 above. General 5. The permissions in this lice nce do not authorise any act which will result in a brea ch of any part of the Russia Regulations, save as permitted under this or other licen ces granted under the Russia Regulations). 6. Information provided to H M Treasury in co nnection with this lice nce shall be disclosed to third parties only in compliance with the UK General Data Prote ction Regulation and the Data Protection Act 2018. 7. This licence takes e ffect from 27 Novem ber 2025 and e xpires on 26 February 2 026 2 5 A ugust 2026. 8. HM Treasury may vary, re voke or suspend t his licence at a ny time. Signed: Office of Financial Sa nctions Imp lementation HM Treasury
27 November 2025 Amended 25 February 2026
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