Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

On January 10, 2025, the US Treasury's Office of Foreign Assets Control (OFAC), acting jointly with the Department of State, designated PJSC Gazprom Neft and PJSC Surgutneftegas as Specially Designated Nationals (SDNs) under Executive Orders 13662 and 14024, alongside more than 180 oil-carrying vessels (the bulk of Russia's "shadow fleet"), dozens of opaque oil traders, two major Russia-based oilfield service providers, marine insurance companies, and senior Russian energy-sector officials. The package included a new EO 14024 sectoral determination authorizing future designations against any person operating in the Russian energy sector, plus a new EO 14071 determination prohibiting the provision of US petroleum services (extraction, drilling, production support) to persons located in the Russian Federation, effective 12:01 a.m. EST on February 27, 2025. OFAC simultaneously issued General Licenses 117 (wind-down of transactions with the newly blocked entities) and 118 (debt/equity/derivatives wind-down), both expiring February 27, 2025. The action was the largest single Russia energy-sector designation since the 2022 invasion regime began and was coordinated with parallel UK OFSI shadow-fleet designations issued the same week. The action was finalized in the closing days of the Biden administration as a deliberate tightening of the oil-revenue and shadow-fleet vectors before the January 20 transition. Subsequent enforcement and any rollback decisions fell to the incoming Trump administration.

Effective 3 March 2022 (retroactive to five days before Federal Register publication), the US Bureau of Industry and Security (BIS) expanded Russian Industry Sector Sanctions under the Export Administration Regulations (EAR) by adding a new license requirement and denial policy for oil refinery equipment destined for or within Russia. The rule creates 15 CFR § 746.5(a)(1)(ii) and a new Supplement No. 4 to Part 746 enumerating approximately 20 categories of refining equipment — from crude distillation units and catalytic crackers to hydrocracking reactors and sulphur recovery units. Applications are subject to a policy of denial, with a narrow health-and-safety exception reviewed case by case. The stated rationale is to limit Russia's ability to generate oil-derived government revenues used to finance its military operations in Ukraine.

On 25 February 2022, the day after Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Regulation (EU) 2022/328, amending Regulation (EU) No 833/2014. It prohibits the sale, supply, transfer or export of dual-use goods and technology to any person, entity or body in Russia, or for military use or military end-users there, and extends to goods and technology suited for use in the oil refining industry and for the aviation and space industry, alongside a ban on related technical assistance, brokering, financing and insurance/maintenance services. The Regulation entered into force on the day after its Official Journal publication (OJ L 49, 25.2.2022), i.e. 26 February 2022.

Angola's President João Lourenço signed Decreto Presidencial n.º 271/20 on 20 October 2020, replacing Order n.º 127/03 of 2003 and establishing the Regime Jurídico do Conteúdo Local do Sector dos Petróleos (RJCLSP). The decree divides petroleum-sector contracting into three regimes — exclusivity (reserved for Angolan nationals and companies), preference (Angolan-majority bidders take priority), and open competition with mandatory local-content scoring — covering all goods and services contracts entered into by concessionaires and their full subcontracting chains. The Ministério dos Recursos Minerais, Petróleo e Gás (MIREMPET) supervises compliance, with non-inclusion of mandatory local-content clauses penalised at USD 50,000–200,000 per infraction and escalating to contract cancellation for repeat offenders. The RJCLSP applies to all IOCs operating Angolan offshore blocks, including TotalEnergies (Block 17), ExxonMobil (Block 15), Chevron (Blocks 0, 14, 14K), BP (Block 31), Eni (Blocks 2, 14, 15/06), and Equinor, as well as their oilfield-services subcontractor chains.