Biden Administration Issues Sweeping Salvo Of Sanctions Against The Russian Energy Sector

On January 10, 2025, in a final action to, among other things, deter Russian aggression on the international stage, the US Department of the Treasury enacted sweeping new sanctions on the Russian energy sector. Specifically, the sanctions package includes:

• Determination authorizing sanctions on any person to operate or have operated in Russia's energy sector;
• Determination banning provision of US petroleum services to Russia and
• Imposition of blocking sanctions against major players in the oil and gas markets, vessels in the so-called "shadow fleet," certain traders of Russian oil, Russian maritime insurers and Russian oilfield service providers.

Below we explain these actions and how they substantially increase the sanctions risks associated with Russian energy both for and beyond the directly impacted entities, as well as the General Licenses (GLs) that accompany the sanctions.