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Key facts
Source:UK OFSI (UK HM Treasury, Open Government Licence v3.0)
The Office of Financial Sanctions Implementation (OFSI) has issued an update to General Licence INT/2025/5635700, which was established under the Russia (Sanctions) (EU Exit) Regulations 2019. The licence provides authorization for certain business operations to continue with specified subsidiaries regarding designated "Exempt Projects."
The recent amendments expand the scope of the licence to include various energy-related infrastructure and projects. New additions to the list of Exempt Projects include the Kurdistan Export Pipeline and the Zohr project. Furthermore, the licence now covers several large-scale operations, specifically the Caspian Pipeline Consortium, TengizChevroil, Shah Deniz, South Caucasus Pipeline, Azerbaijan Gas Supply Company, and Karachaganak.
The update also adjusts the definition of "Relevant Subsidiary" to account for recent UK designations. The licence now applies to any entity that is directly or indirectly owned or controlled by PJSC Transneft, PJSC Lukoil Oil Company, or PJSC Rosneft Oil Company.
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