Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 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.

President Trump signed Executive Order 14324, "Suspending Duty-Free De Minimis Treatment for All Countries," on 30 July 2025 (published in the Federal Register on 5 August 2025 as FR doc 2025-14897, 90 FR 37775). The order eliminated the Section 321(a)(2)(C) administrative exemption that had allowed shipments valued at $800 or less to enter the United States duty-free, applying the suspension to all countries of origin rather than the China/Hong Kong-only carve-out imposed earlier in 2025. DHS/CBP published a Notice of Implementation on 2 September 2025 (FR doc 2025-16802) modifying the Harmonized Tariff Schedule so that covered low-value goods must be entered via formal or informal ACE entry types and pay applicable duties; goods shipped through the international postal network were instead made subject to a new flat ad valorem or specific per-item duty rate set by HTSUS annex. The suspension took effect for entries on or after 12:01 a.m. EDT on 29 August 2025. A DHS/CBP rule published 24 June 2026 (FR doc 2026-12670) converted the non-postal suspension from time-limited to indefinite and closed the remaining international-postal-network exemption to formal/ informal entry procedures as well.