uk-sanctions 27 November 2025

UK extends sanctions exemption for Lukoil Bulgaria subsidiaries

The United Kingdom has expanded its sanctions exemption for Lukoil’s Bulgarian operations, adding two subsidiaries to a temporary general licence that allows continued business with the Russian oil company’s assets despite UK sanctions, the Office of Financial Sanctions Implementation announced.

The amended General Licence INT/2025/7895596 covers Lukoil Aviation Bulgaria EOOD and Lukoil Bulgaria Bunker EOOD, in addition to Lukoil Bulgaria EOOD and Lukoil Neftochim Burgas AD that were included when the licence was originally issued on 14 November.

The authorisation allows payments and economic transactions involving these entities and their subsidiaries through 14 February 2026.

The expansion follows Bulgaria’s appointment of a special commercial administrator to oversee Lukoil’s four operations in the country, including the Neftochim Burgas refinery and hundreds of petrol stations. On 14 November, Bulgaria named Rumen Spetsov, former executive director of the National Revenue Agency, as special administrator with powers to manage the companies following the imposition of sanctions.

The United States has also issued multiple exemptions for Lukoil operations, including General Licence 130 authorising transactions with the four Bulgarian subsidiaries until 29 April 2026. The US Treasury Department’s Office of Foreign Assets Control issued additional licences allowing negotiations for the sale of Lukoil International GmbH until 13 December and permitting the operation of Lukoil retail service stations outside Russia until the same date.

The UK imposed sanctions on Lukoil on 15 October as part of measures targeting Russia’s energy sector over the invasion of Ukraine, while the US designated Lukoil and fellow Russian oil giant Rosneft a week later, prompting the company to announce it plans to sell its international assets.

The US sanctions sent shockwaves across Europe, forcing countries from Romania to Bulgaria, the Netherlands, and Finland to confront difficult decisions about Russian energy assets, with Finland’s Neste suspending fuel deliveries to Lukoil-owned Teboil and multiple governments scrambling to secure exemptions or arrange forced sales of refineries and fuel station networks.

Bulgaria’s concerns about fuel supplies ahead of winter prompted urgent negotiations with US and UK authorities to secure exemptions for the country’s operations. The Neftochim Burgas refinery supplies fuel to much of Bulgaria, while Lukoil operates a vast chain of petrol stations in the country.

Lukoil said it is ‘taking all necessary steps to complete the sale of the refinery, the filling stations network and other assets in Bulgaria to a new owner and expects that the activities of the external administrator will not impede this process’. The company said it ‘reserves the right to seek judicial remedies to protect its rights and legitimate interests in the event of their violation.’​