Lukoil Bulgaria Entities General Licence Continuation of Business

OFSI General Licences

Published November 14th, 2025

Detected March 6th, 2026

Summary

HM Treasury has amended the General Licence concerning the continuation of business for Lukoil Bulgaria entities. This amendment extends the licence, allowing specified business operations to continue under certain conditions until February 13, 2026.

View original document View source feed page

What changed

HM Treasury, through the Office of Financial Sanctions Implementation, has amended the General Licence INT/2025/7895596, originally granted under the Russia (Sanctions) (EU Exit) Regulations 2019. The amendment, dated February 10, 2026, extends the permissions for "Persons" and "Relevant UK Institutions" to continue business operations involving the "Lukoil Bulgaria entities" and their subsidiaries. These operations include making and receiving payments and providing economic resources, subject to the conditions outlined in the licence. The licence now expires on February 13, 2026, with the latest amendment date being February 10, 2026.

This amendment provides a critical, albeit temporary, window for regulated entities to continue specific business dealings with the Lukoil Bulgaria entities. Compliance officers must ensure that all activities conducted under this licence strictly adhere to its terms and conditions, and do not breach any other UK sanctions regulations. The extended deadline of February 13, 2026, requires careful management of ongoing contractual obligations and financial transactions. Entities should review their existing relationships and processes to ensure full compliance during this period.

What to do next

Review existing contracts and obligations with Lukoil Bulgaria entities.
Ensure all payments and provision of economic resources comply with the licence terms.
Confirm that activities do not breach any other UK sanctions regulations.

Source document (simplified)

GENERAL LICENC E – Continuation of Business of Lukoil Bulgaria Entitie s INT/2025/7895596 1. This licence is gra nted under re gulation 64 of t he Russia (Sa nctions) (EU E xit) Regulations 2019 (“the Russia Regulatio ns”). 2. Any act which would ot herwise breach the prohibitio ns in Regulations 11 to 17 and 18C of t he Russia Regulations is exempt from those prohibiti ons to the extent required to give effect to the permissions in this licen ce. 3. In this licence: The “Lukoil Bulgar ia entities ” means Lukoil Bulgaria EOO D; Lukoil Neftochim Burga s AD; Lukoil Aviation Bulgaria EO OD; and Lukoil Bunker Bulgaria E OOD which are subsidiaries of PJ SC Lukoil. ” Their Subsidiaries ” means Any entity owned or co ntrolled, directly or indire ctly, by the Lukoil Bulgaria entities w ithin the meaning of reg ulation 7 of the Russia Regulations. a “ Person ” means An individual, a body o f persons corporate or unincorporate, any organisation or a ny association 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 the L ukoil Bulgaria entities. 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 operatio ns involving the Lukoil Bulgaria entitie s and Their Subsidiaries including, but not limited to: 4.1.1. Payments to or from the Lukoil B ulgaria entities under any existi ng 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, and re ceipt of, economic resources from the Lukoil B ulgaria entities. 4.2. A Relevant UK Institutio n may process pa yments made in accorda nce with paragra phs 4.1.1 - 4.1.3 above. General 5. This licence applies to the Russia Regulations only an d authorises acts otherwise prohibited by t he Russia Regulations. T his licence does not a uthorise any act which would re sult in a breach of any other UK sanctions regulations (regulations made under section 1 of the Sanctions and Anti-Money Laundering Act 2018). 6. Information pro vided t o H M Trea sury in co nnection with this licence shall be disclosed to third parties only in compliance with the UK General Data Protection Regulatio n and the Data Protection Act 2018. 7. This licence takes e ffect from 1 4 No vember 2025 and e xpires on 14 Februar y 2026 13 August 20 26. 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 14 November 2025 Amended 20 Nove mber 2025. Amended 10 February 2026.