US issues temporary exemptions for Rosneft’s German subsidiaries until April 2026

The US Treasury Department has issued a temporary exemption allowing transactions with two German subsidiaries of sanctioned Russian oil giant Rosneft until 29 April 2026, underscoring the complex interplay between US and EU sanctions enforcement amid ongoing energy security concerns.

Treasury’s Office of Foreign Assets Control (‘OFAC’) published General Licence No. 129 on Wednesday, authorising dealings with Rosneft Deutschland GmbH and RN Refining & Marketing GmbH, as well as any entities in which they hold a 50% or greater interest. The licence does not extend to other blocked affiliates of Rosneft Oil Company unless separately authorised.

The exemption follows the US government’s broader sanctions package announced on 22 October, which added Rosneft and Lukoil to the Specially Designated Nationals list, effectively freezing their assets and prohibiting US persons from engaging in transactions. The move aligns with similar actions taken by the United Kingdom, which issued General Licence INT/2025/7598960 to preserve operations at key refineries in Germany until 22 October 2027, longer than the permission granted by OFAC.

‘The new US sanctioning of Lukoil and Rosneft will once again emphasise the conflict between EU and US law,’ said Mareike Heesing, a sanctions lawyer at Oppenhoff & Partner in Cologne. She noted that under EU law, the entities have already been sanctioned, but Rosneft Germany remains under trust management by the German Federal Network Agency Bundesnetzagentur, effectively severed from its Russian parent.

The licence aims to prevent disruption at strategic energy facilities, including the Schwedt refinery, which supplies fuel to Berlin and eastern Germany. Analysts warn, however, that the exemptions may complicate compliance for multinational firms navigating divergent sanctions regimes.

Since the US sanctioned Lukoil earlier this month, the Russian oil giant has begun divesting its overseas assets, triggering market turmoil in several European countries, particularly Slovakia and Hungary.