OFSI Adds Kurdistan Pipeline to Russian Oil Licence

LONDON, July 31, 2026 — The UK widened a project-specific exception under its Russia sanctions program by adding the Kurdistan Export Pipeline to a general licence covering certain business operations and payments.

General Licence INT/2025/5635700 permits people and businesses that are not designated persons to continue operations involving specified projects and relevant subsidiaries. The latter category covers Gazpromneft-Sakhalin LLC and entities it owns or controls, as well as entities owned or controlled by PJSC Lukoil Oil Company, PJSC Rosneft Oil Company and PJSC Transneft.

The permitted activity includes payments to or from relevant subsidiaries or third parties under new or existing obligations and contracts, provided the transactions relate to an exempt project. Relevant UK financial institutions may process payments made under those permissions.

The licence also allows certain business operations and shareholder rights where an exempt project’s share registrar is a designated person. That includes paying administrative fees for registrar services and receiving dividends processed by or with reference to the registrar, but it does not permit share sales.

The Kurdistan Export Pipeline exemption applies from July 31, 2026, through Oct.14, 2027. The licence requires records of covered activity to be kept for at least six years and does not authorize conduct that breaches other parts of the Russia sanctions regulations.

For compliance teams, the amendment expands the set of energy projects that can support licensed transactions while retaining project-specific time limits and conditions.

OFSI adds Kurdistan pipeline to Russian oil licence

Regulatory Actions

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Primary Documents

Annexes & Supporting Documents

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Regulatory Actions

License Action3 subjectsOn 10 January 2025, OFSI issued General Licence INT/2025/5635700 under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, allowing continuation of business operations with the Relevant Subsidiary to the extent they relate to the Exempt Projects.

Amendment1 subjectOn 27 June 2025, the Sakhalin-2 Exemption was extended.

Amendment9 subjectsOn 15 October 2025, the definition of a Relevant Subsidiary was updated to include any entity owned or controlled, directly or indirectly, by PJSC Lukoil Oil Company or PJSC Rosneft Oil Company, and six projects were added to the list of Exempt Projects.

Amendment2 subjectsOn 17 December 2025, Schedule 1 was amended to add the Zohr project, and the permissions were amended to authorise continued business operations and exercise of shareholder rights in relation to an Exempt Project where the share registrar is a Designated Person.

Amendment3 subjectsOn 24 February 2026, the definition of a Relevant Subsidiary was updated to include any entity owned or controlled, directly or indirectly, by PJSC Transneft, and Schedule 1 was amended to add the Druzhba Pipeline.

Amendment2 subjectsOn 31 July 2026, Schedule 1 of the General Licence was amended to add the Kurdistan Export Pipeline to the list of Exempt Projects.