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World risk · Trade, tariffs and sanctions · Russia, Ukraine & NATO

The US eases sanctions on Russia's oil majors while the EU keeps its Russia sanctions

The test Between 26 Oct 2026 and 25 Oct 2027, OFAC removes from the SDN list a parent company of the Russian oil majors it designated on 22 Oct 2025, or issues a general licence authorising dealings with such a parent or its new crude and product sales (not a wind-down, a divestment, a ring-fenced foreign subsidiary or cargo already loaded), while the EU's Russia economic sanctions stay in force.

Not under way · Confidence: medium · Reviewed 25 Oct 2026 · Scores from 1 to 10

This page answers: What could happen, how it is scored, and who is exposed?

Using this page
  1. Read the two scores: Likelihood and Impact are kept apart.
  2. Check what is happening, each fact with its source.
  3. Use the calendar for the dates to watch.

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Likelihood
4Elevated steady this month
Impact
5Elevated steady this month
Breadth6
Depth3
Duration7
Hard to substitute5
Canada pointNot added0

Impact is the average of the four parts, rounded, plus one point when Canada is directly hit on two or more channels, up to 10.

Two separate scales from 1 to 10. Strature never multiplies or merges them.

What changed

Dated, newest first

  1. Likelihood trend up to flat.
  2. GL 131K authorises negotiation of contingent contracts for the sale of Lukoil International GmbH. [5]
  3. EO 14024 sanctions are unaffected by the waiver; GL 135 of 9 Oct 2026 allows Russian diesel imports to 7 Apr 2027. [3]
  4. The president waived the Graham Act measures indefinitely, after recently announcing a diesel deal with Russia. [2]
  5. GL 130B authorises dealings with four Lukoil entities in Bulgaria to 24 Apr 2027. [6]
  6. NYT reported (via Kyiv Independent) that Putin raised a Lukoil asset deal with Witkoff and Kushner on 5 Sep 2026. [9]
Show 2 earlier changes
  1. In September 2026 Hungary was the EU's largest buyer of Russian fossil fuels, EUR 475m. [14]
  2. Russian crude export revenue EUR 339m a day in Sept 2026; Urals USD 23 below Brent. [14]

Why it matters

The US blocked Russia's two largest oil companies on 22 October 2025. A year on, Washington has waived new Russia measures, licensed Russian diesel imports and is reported to be discussing a deal on one of the two with Moscow, while the EU has renewed its economic sanctions to 31 July 2027. If the US lifts or broadly licenses either, banks, shippers and insurers would face two rulebooks.

Why Likelihood 4 Drivers in place: Putin's reported Lukoil proposal (NYT via Kyiv Independent), the 2026 oil-at-sea licences, the waiver and diesel licence, a pending Carlyle sale. Brakes: EO 14024 untouched, anger in Congress, stalled talks; a sale licence is the easier path and does not count.

Why Impact 5 Threshold case: one of the two majors delisted or broadly licensed. Key price: Urals discount to Brent, USD 23 in Sept 2026. Russian crude revenue about EUR 124bn a year (about US$139bn at the ECB rate of 23 Oct 2026), gross and wider than one company.

The other facts on file (4)
  • OFAC designated Rosneft and Lukoil and 34 subsidiaries under EO 14024. [1] (22 Oct 2025)
  • After the Iran war disrupted energy markets, GL 134B licensed sales of Russian-origin oil loaded by 17 Apr 2026, to 16 May 2026. [7] (17 Apr 2026)
  • The EU's 19th package ended the exemption for Rosneft and Gazprom Neft oil and gas imports. [11] (23 Oct 2025)
  • The EU renewed its economic sanctions on Russia for 12 months, to 31 Jul 2027. [13] (25 Jun 2026)

Where it sits

11. The US eases sanctions on Russia's oil majors while the EU keeps its Russia sanctions: Elevated impact · possible1 · Elevated impact · possibleMoscowKyivWarsawAUSTRIABULGARIABELARUSCZECH REPUBLICGERMANYESTONIAFINLANDHUNGARYITALYKAZAKHSTANLITHUANIALATVIANORWAYPOLANDROMANIARUSSIASERBIASWEDENUKRAINEUZBEKISTANBLACK SEA0500 kmat 52°NMap data: Natural Earth (public domain).
11. The US eases sanctions on Russia's oil majors while the EU keeps its Russia sanctions: Elevated impact · possibleMoscowKyivAUSTRIABULGARIABELARUSCZECH REPUBLICESTONIAFINLANDHUNGARYLITHUANIALATVIAPOLANDROMANIARUSSIASERBIASWEDENUKRAINE0300 kmat 52°NMap data: Natural Earth (public domain).

How it spreads

If

Between 26 Oct 2026 and 25 Oct 2027, OFAC removes from the SDN list a parent company of the Russian oil majors it designated on 22 Oct 2025, or issues a general licence authorising dealings with such a parent or its new crude and product sales (not a wind-down, a divestment, a ring-fenced foreign subsidiary or cargo already loaded), while the EU's Russia economic sanctions stay in force.

Not under way

Channels 4 on the card

  1. CanadaNo Canadian loss on file; Canada would choose whether to follow the US or the EU.
  2. ComplianceEU and UK banks, insurers and shippers could not follow US firms into Rosneft or Lukoil trades.
  3. Oil prices and flowsA US licence could narrow the Urals discount and move more Russian oil through US-linked traders.
  4. The EUThe EU's leverage weakens as the main G7 partner steps away.

Sectors 3

  • Banks and insurers
  • Energy and pipelines
  • Ports and logistics

Who is exposed

Countries
Russia, United States, Bulgaria, Hungary, India, China, Turkey
Sectors
Banks and insurers, Energy and pipelines, Ports and logistics
Goods
Crude oil, Refined fuels
Companies
Rosneft, Lukoil, Carlyle

Three scenarios and their signposts

  1. S1

    Narrow licences only

    OFAC keeps renewing wind-down and sale licences; the split stays technical.

  2. S2

    The Lukoil deal

    A US-Russia deal lifts sanctions on Lukoil assets.

  3. S3

    Re-tightening

    Talks fail; the US keeps or adds listings and the split does not open.

The signposts of each scenario
PathSignpost
S1GL 131K replaced by a sale licence, not a delisting
S2An OFAC delisting notice or a broad Lukoil licence after the November round
S3No Russia-Ukraine round held by 31 Dec 2026

No probability is given for the three paths.

Dates to watch

Calendar

The dates to watch

A dot is a day, a bar a month or a year; a hollow mark is tentative. The line marks today.

  1. Nov 2026 Fourth Russia-Ukraine round, probably Abu Dhabi [15] Tentative · Outside event
  2. 3 Nov 2026 US midterm elections; Congress returns afterwards [2] Declared · Outside event

    Remind me

  3. 7 Apr 2027 OFAC GL 135 on Russian diesel imports expires [3] Declared · Outside event

    Remind me

  4. 24 Apr 2027 OFAC GL 130B (Lukoil Bulgaria) expires [6] Declared · Outside event

    Remind me

  5. 31 Jul 2027 EU economic sanctions on Russia expire unless renewed [13] Declared · Outside event

    Remind me

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SourceStrature world-risk card; the dates cite the sources below.
Exhibit R-3 · WORLD · strature.net

The other side

A licensed Lukoil sale to a Western buyer would move refineries and stations out of Russian control, which the US and the EU both seek. Cheaper oil would help importers.

Connected in Strature

Sources

11 sources, numbered as the text cites them

  1. Treasury Sanctions Major Russian Oil Companies, Calls on Moscow to Immediately Agree to Ceasefire. US Department of the Treasury · 22 Oct 2025 · Official · confidence high · retrieved 25 Oct 2026
  2. Trump's decision to waive Russian sanctions outrages Congress, but no quick counter seen. AP via PBS NewsHour · 17 Oct 2026 · News · confidence high · retrieved 25 Oct 2026
  3. President Trump waives new Russia sanctions and tariffs under the Graham Act. Clyde & Co · 21 Oct 2026 · Commentary · confidence medium · retrieved 25 Oct 2026
  4. Recent actions, 21 October 2026: General License 131K. US Treasury OFAC · 21 Oct 2026 · Official · confidence high · retrieved 25 Oct 2026
  5. General License No. 130B, Certain Lukoil Entities in Bulgaria. US Treasury OFAC · 15 Oct 2026 · Official · confidence high · retrieved 25 Oct 2026
  6. OFAC issues General License 134B extending authorization for certain Russia-origin crude oil and petroleum product transactions. Baker McKenzie · 20 Apr 2026 · Commentary · confidence medium · retrieved 25 Oct 2026
  7. US peace negotiations with Russia could now involve multi-billion dollar Lukoil deal, NYT reports. Kyiv Independent · 4 Oct 2026 · News · confidence medium · retrieved 25 Oct 2026
  8. EU adopts 19th package of sanctions against Russia. European Commission (DG FISMA) · 23 Oct 2025 · Official · confidence high · retrieved 25 Oct 2026
  9. The Council of the European Union has officially extended economic sanctions against Russia through July 2027. Liga.net · 25 Jun 2026 · News · confidence medium · retrieved 25 Oct 2026
  10. September 2026: Monthly analysis of Russian fossil fuel exports and sanctions. CREA · 20 Oct 2026 · Think tank · confidence high · retrieved 25 Oct 2026
  11. Ukraine and Russia eye new peace talks, but steep obstacles remain. AP via MPR News · 24 Oct 2026 · News · confidence high · retrieved 25 Oct 2026

Reviewed 25 Oct 2026 · version 1 · last change: reviewed · All risks