UK extends Lukoil Bulgaria sanctions licence, adds notification requirement

LONDON, Aug. 12, 2026 — The UK Office of Financial Sanctions Implementation amended General Licence INT/2025/7895596, extending its validity from Aug. 13 until Oct. 29, 2026, and introducing new compliance requirements for entities relying on the licence.

The licence permits continued business operations involving Lukoil Bulgaria EOOD, Lukoil Neftochim Burgas AD, Lukoil Aviation Bulgaria EOOD and Lukoil Bunker Bulgaria EOOD, including certain payments, contractual obligations and the provision or receipt of economic resources. Relevant UK financial institutions may process payments permitted under the licence.

Under the Aug. 12 amendment, an “Entity,” defined as a person that is neither an individual nor a Relevant UK Institution, must notify HM Treasury when conducting activities under the licence. Entities beginning such activity on or after Aug. 12 must notify OFSI within 14 days of commencement. Those already conducting permitted activity must notify OFSI within 14 days of Aug. 12 and provide current contact details.

OFSI also said the definition of “Their Subsidiaries” had been amended. Its GOV.UK update and publication notice state that the term now covers non-individual persons owned or controlled, directly or indirectly, by Lukoil International.

However, the amended general licence PDF posted by OFSI appears to contain different wording, defining “Their Subsidiaries” by reference to ownership or control by the Lukoil Bulgaria entities. Market participants may therefore wish to check the operative licence wording and any subsequent OFSI clarification before relying on the expanded scope.

The licence was originally issued Nov. 14, 2025, under the Russia (Sanctions) (EU Exit) Regulations 2019.