US and UK regulators issue licences pertaining to Russia-related energy projects

On 27 June 2025, OFSI amended General Licence INT/2025/5635700 and General Licence INT/2022/2470156 as relate to an exemption on the restrictions of oil supplies coming from the Sakhalin-2 project, which is an oil and gas development in Sakhalin island, Russia  Further, on the same day, OFAC issued  General License No. 115B authorising certain transactions relating to civil nuclear energy.

General Licence INT/2025/5635700 is issued in accordance with Regulation 64 of The Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Regulations”) to provide for the continuation of business operations with Gazpromneft-Sakhalin LLC and any entity owned or controlled, directly or indirectly by them (“the Relevant Subsidiary”) in relation to the Sakhalin-2 project (“the Exempt Projects”). The Licence permits anyone, who is not a designated person themselves, to make or receive any payments under any new or existing obligations or contracts with Gazpromneft-Sakhalin LLC (and entities owned or controlled by it within the meaning of Regulation 7 of Russia Regulations), provided that those payments are in relation to the Sakhalin-2 project. The latest amendment extends the authorisation for setting Sakhalin-2 as an exempt project per  Schedule 1 of that Licence by 12 months until 28 June 2026.

General Licence INT/2022/2470156 permitsthe supply or delivery by ship of Russian oil originating from the Sakhalin-2 project in Russia to Japan (Schedule 1 to that Licence). It also permits the provision of services relating to the supply or delivery of Russian oil by ship from a place in Russia to a place in Japan. Additionally, the Licence authorises the purchase, import or transfer of Russian oil to Bulgaria under contracts concluded before 4 June 2022 (Schedule 2 to that Licence). The recent amendment extends the expiration of the Sakhalin-2 exemption in Schedule 1 by 12 months until 28 June 2026.

On 27 June, OFAC issued Russia-related General License No 115B, “Authorizing Certain Transactions Related to Civil Nuclear Energy,” as well as updating the relevant FAQs. The General Licence No. 115B permits certain transactions relating to civil nuclear energy and involving designated Russian banks, provided that those are specifically required for maintenance or support of civil nuclear projects that were initiated before 21 November 2024. The prohibited transactions are authorised till 19 December 2025.

Updated: 2 July 2025

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