The UK’s Office of Financial Sanctions Implementation has issued a temporary general licence allowing eligible parties to wind down or divest from transactions involving Zarubezhneft JSC and entities it owns or controls. The authorisation took effect on 8 October 2026 and expires at 23:59 on 21 November 2026.
The licence applies to transactions involving Zarubezhneft or a covered subsidiary where the person seeking to exit is a party to that transaction. It expressly includes closing out positions. A subsidiary can be incorporated anywhere in the world, provided it is owned or controlled, directly or indirectly, by Zarubezhneft within the meaning set out in the Russia sanctions regulations.
It also permits a person, a relevant UK institution or the designated party itself to carry out activity reasonably necessary to complete the permitted wind-down or divestment. The licence defines relevant UK institutions to include certain regulated financial-services firms, payment and electronic-money providers, recognised clearing houses and securities depositories, and operators or service providers of recognised payment systems. These defined classes do not make the permission universal for every organisation or every transaction.
A narrow, temporary permission
A general licence is a standing authorisation for specified activity when its terms are met; it is not a removal of the underlying sanctions designation. This one provides a limited route to close or divest qualifying dealings during a defined period. It does not provide blanket permission to continue ordinary business with Zarubezhneft or its controlled subsidiaries after an exit, nor does it authorise every step a counterparty might find commercially convenient.
The text limits the permission to the activities it describes and says it does not authorise conduct that would breach other parts of the Russia sanctions regulations, except where this or another licence allows it. In practical terms, the relevant question is whether the transaction, party and proposed step fall within the licence’s definitions and permissions. A related activity that is not reasonably necessary to effect the exit is not made permissible simply because it occurs during the same period.
The authorisation follows the addition of Zarubezhneft to the UK sanctions framework. That designation is the wider context for the licence, but the wind-down measure is a distinct, temporary provision intended to deal with existing transactions. It sets an endpoint for the permitted exit rather than creating an open-ended exemption from sanctions restrictions.
Records and the deadline
Any designated party, person or relevant UK institution undertaking activity permitted—or purported to be permitted—under the licence must keep accurate, complete and readable records of that activity for at least six years. Records may be held on paper or electronically. The requirement makes it important for anyone relying on the permission to preserve a clear account of what was done and how it related to the authorised wind-down.
The deadline is 23:59 on 21 November 2026. HM Treasury may vary, revoke or suspend the licence at any time, so the document does not guarantee that its terms will remain unchanged until expiry. The publication notice directs users to the licence itself for the full definitions, permissions and conditions.
This is a description of the published authorisation, not advice on whether a particular transaction qualifies. Its narrow scope, short duration and record-keeping condition distinguish it from a general easing of UK Russia sanctions. The key points are the covered counterparties, the requirement that the person be party to the transaction, the limited ancillary steps, and the fixed exit window.
