Summary
On 15 October 2025, the UK imposed asset freeze measures against several entities under the Russia (Sanctions) (EU Exit) Regulations 2019 (the UK Russia Sanctions) – these measures included but were not limited to asset freezes against entities such as PJSC Rosneft Oil Company (Rosneft) and PJSC Oil Company Lukoil (Lukoil).
- The US followed with sanctions against Rosneft and Lukoil on 22 October 2025 along with several Rosneft and Lukoil subsidiary entities. Various licences were also issued to address specific short term issues.
- The EU also imposed sanctions against several entities on 23 October 2025. While the EU did not impose asset freezes against either Rosneft or Lukoil, the EU transaction ban against Rosneft was tightened considerably.
- EU Sanctions
- These latest sanctions have the following effects:
- targeting key sectors which fuel Russia’s illegal invasion of Ukraine, including energy, finance and the military industrial complex;
- imposing further measures on Belarus to restrict Belarussian support for the Russian war effort;
- targeting Russian energy, banks, crypto exchanges and entities in China, among others;
- introducing a ban on imports of Russian LNG into the EU starting in January 2027 for long-term contracts and within six months for short-term contracts and tightening the existing transaction ban on two major Russian state-owned oil producers (Rosneft and Gazprom Neft);
- adopting measures against important third country operators enabling Russia’s revenue streams including the imposition of sanctions against various Chinese entities – two refineries and an oil trader – that are significant buyers of Russian crude oil;
- imposing additional sanctions across the shadow fleet value chain (this relates to the imposition of asset freezes against Litasco Middle East DMCC, maritime registries providing false flags to shadow fleet vessels and the imposition of transaction bans against 2 oil trading companies in Hong Kong and the UAE);
- imposing a port ban and a ban on the provision of a broad range of services related to maritime transport against 117 vessels;
- making Litasco Middle East DMCC subject to the asset freeze measures;
- imposing a ban on reinsuring vessels which are included in Annex XLII to the EU Regulation and which includes amongst others, vessels said to have transported crude oil or petroleum products or mineral products that originate in Russia or are exported from Russia and practice irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly resolution A.1192(33);
- extending the EU transaction ban to five Russian banks and eight banks and oil traders from Tajikistan, Kyrgyzstan, the UAE and Hong Kong;
- expanding export controls on electronic components, military-grade metals and industrial goods;
- imposing import restrictions on additional metals, oxides and alloys used in the military systems and acyclic hydrocarbons;
- imposing sanctions on maritime registries providing false flags to shadow fleet vessels; and
- requiring prior authorization for any services provided to the Russian Government not already covered by EU Regulation 833/2014.
UK Sanctions
Rosneft and Lukoil were added to the UK asset freeze list. Asset freezes were imposed against an additional 90 asset freeze targets, including:
- four Chinese oil terminals;
- an Indian entity – Nayara Energy Limited;
- 51 tankers and LNG carriers;
- five Russian financial institutions;
- a number of entities in the defence sector;
The UK has also adopted a number of General Licences to allow for wind-down transactions involving these entities in certain circumstances:
- General Licence INT/2025/7539056 allowing for the winding down of transactions involving Rosneft, Lukoil and their subsidiary entities;
- General Licence INT/2025/7538856 allowing for the winding down of transactions involving certain energy entities, including Nayara Energy Limited. This licence expired at 23:59 on 13 November 2025 and can no longer be relied on; and
- General Licence INT/2025/7598960 authoring business transactions involving two German Rosneft subsidiaries who are operating under the supervision of the German government – Rosneft Deutschland GmbH and RN Refining and Marketing GmbH.
US Sanctions
- OFAC has imposed asset freezes against Russia’s two largest oil majors – Rosneft and Lukoil – who have been added to the US SDN list along with several subsidiary entities;
- all entities owned 50% or more by either company are blocked;
- Russia-related General License 124A “Authorizing Petroleum Services and Other Transactions Related to the Caspian Pipeline Consortium and Tengizchevroil Projects” has been issued authorizing transactions with Rosneft, Lukoil and their subsidiary entities;
- Russia-related General License 126 “Authorizing the Wind Down of Transactions Involving Rosneft or Lukoil” has been issued allowing for the winding down of transactions involving Rosneft or Lukoil until 21 November 2025;
- Russia-related General License 127 “Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Rosneft or Lukoil” permits all transactions necessary to the divestment or transfer of debt or equity issued or guaranteed by Rosneft, Lukoil and their subsidiary entities;
- Russia-related General License 128 “Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia” has been issued authorizing transactions involving Lukoil retail service stations located outside of Russia until 21 November 2025; and
- Russia-related General License 129 “Authorizing Transactions Involving Rosneft Deutschland GmbH and RN Refining and Marketing GmbH” has been issued authorizing transactions involving Rosneft Deutschland GmbH and RN Refining and Marketing GmbH through 29 April 2026.
MMIA’s Policy
MMIA has adopted a policy not to insure any tankers which are engaged in the carriage of cargoes of crude oil or refined petroleum products that originate in Russia or are exported from Russia, even if those products comply with the oil price cap mechanism. MMIA also will not insure any vessels which have been identified as forming part of the dark fleet or shadow fleet.
MMIA notes the adoption of further UK, US and EU sanctions against Russia. Of particular importance are the measures taken against Rosneft and Lukoil which also cover their subsidiary entities (such as Litasco Middle East DMCC). Subject to any wind-down provisions, Members must ensure that they have terminated all commercial and contractual relationships – including charter parties – with these entities and discharged any cargoes where these entities may be the cargo owner by the expiry date of those General Licences (ie at the latest by 21 November 2025).
Cover is not available for any trade that breaches applicable sanctions. Thorough due diligence must be conducted on the parties, cargoes, vessels and other service providers that are or may be involved before they engage in any trade with a high sanctions risk. Members should keep records of any and all due diligence conducted.
Yours faithfully,
The Board of Directors
Maritime Mutual Insurance Association (NZ) Limited