EU Adopts 21st Russia Sanctions Package; OFAC Issues Lukoil GL 131H
Companies with Russia or Belarus exposure must reassess contracts, shipping, and financial flows after the EU's 21st sanctions package and OFAC's Lukoil license update.
On July 23, 2026, the EU Council adopted its 21st sanctions package against Russia, expanding measures targeting energy revenues, the military-industrial complex, financial services, the shadow fleet, and critical infrastructure. The package amends Regulation 269 (asset freezes) and Regulation 833 (trade restrictions), and adds parallel Belarus restrictions under new Council regulations and decisions, including asset freeze designations and trade measures mirroring those against Russia. Separately, on July 24, 2026, OFAC issued Russia-related General License 131H, authorizing certain transactions tied to negotiating and entering contingent contracts for the sale of Lukoil International GmbH and related maintenance activities, and amended FAQs 1224 and 1225. In-house counsel should map counterparties against the new EU designations, review shipping and financial arrangements for shadow-fleet and critical-infrastructure exposure, and evaluate any Lukoil-related transactions for GL 131H eligibility.