The UK's Office of Financial Sanctions Implementation (OFSI) has made several amendments to General Licence INT/2025/5635700, which was originally issued on 10 January 2025. This licence operates under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019.
The licence allows for the continuation of business operations with specific relevant subsidiaries, provided these operations are related to designated exempt projects. The Kurdistan Export Pipeline and the Zohr project have both been added to the list of exempt projects.
Further amendments have expanded the definition of a Relevant Subsidiary to include entities owned or controlled, directly or indirectly, by PJSC Transneft, PJSC Lukoil Oil Company, or PJSC Rosneft Oil Company, following their designation by the UK. Additionally, projects such as Caspian Pipeline Consortium, TengizChevroil, Shah Deniz, South Caucasus Pipeline, Azerbaijan Gas Supply Company, and Karachaganak have been added to the list of Exempt Projects in Schedule 1 of the General Licence.