Industrial Policy & Trade Monitor· 2665 actions· ✨ 90 recent

On October 22, 2025, the US Treasury's Office of Foreign Assets Control (OFAC) added Open Joint Stock Company Rosneft Oil Company ("Rosneft") and Lukoil OAO ("Lukoil") — together with dozens of named Russia-based subsidiaries — to the Specially Designated Nationals (SDN) List under Executive Order 14024 for "operating or having operated in the energy sector of the Russian Federation economy." It is the first US designation of Russia's two largest integrated oil majors since the 2022 invasion-era sanctions architecture began. Under OFAC's 50% Rule, the blocking extends automatically to all entities owned 50% or more, directly or indirectly, by Rosneft or Lukoil — capturing a sprawling global subsidiary network including Lukoil retail/refining assets in Belgium, Netherlands, Bulgaria, Romania, Italy, Finland, the West Qurna-2 upstream stake in Iraq, and Lukoil Americas. Rosneft and Lukoil together account for roughly half of Russian crude exports (~5 mb/d combined production) and Lukoil holds a ~9% European retail-fuel market share. OFAC simultaneously issued General License 124 (Caspian Pipeline Consortium / Tengizchevroil / Karachaganak Kazakhstan-pipeline carve-out, no expiry), General License 125 (Lukoil retail service stations outside Russia, wind-down to November 21, 2025), General License 126 (general wind-down to November 21, 2025) and General License 127 (debt/equity divestment and derivatives wind-down to November 21, 2025). GL 131 (issued November 14, 2025) opened a divestment window for Lukoil International GmbH; subsequent GL 134/134A/134B extended cargo-offload authorisations through April–May 2026. The action was coordinated same-day with UK OFSI Rosneft/Lukoil designations and the EU's 19th Russia sanctions package adopted October 23, 2025 — the first major US-led Russia-energy escalation under the second Trump administration.

On 27 December 2017 President Nursultan Nazarbayev signed Code No. 125-VI ZRK "On Subsoil and Subsoil Use," a wholesale recodification replacing the 2010 Subsoil Use Law that entered into force on 29 June 2018 (with certain provisions deferred to 1 January 2019). The Code establishes the licensing architecture for all mineral extraction in Kazakhstan — the world's leading uranium producer (~40% of global U₃O₈ output, ~22,000 tU/yr) and a top-11 oil exporter (~1.8 mbpd) — covering solid minerals, hydrocarbons, and uranium under a single codified framework. For solid minerals the Code introduces a liberalised "first-come first-served" auction-free licence model for non-strategic deposits and a state-tender model for strategic deposits, alongside subsoil-use rights transfer and pledge provisions governing all M&A in the sector. For uranium the Code codifies the National Atomic Company Kazatomprom's statutory role as state operator over all uranium blocks, with government priority pre-emption rights and mandatory Kazatomprom participation in all production licences. For hydrocarbons the Code establishes the concession and production-sharing framework governing the pre-salt Caspian mega-projects (Tengiz, Karachaganak, Kashagan) and the model contract architecture for petroleum products. Horizontal obligations — local Kazakh-content procurement floors, social-package requirements, and environmental-restoration mine-closure security — apply across all subsoil-use categories. Structurally this Code is the parent statute for every subsequently filed KZ action: the 2023-12-28 REE Comprehensive Plan and the 2025-12-26 Kazatomprom uranium-priority amendments both operate under delegated authority created by this Code.