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US extends Lukoil Bulgaria sanctions exemptions to April 2027

OFAC general licences extend operating room for Bulgarian assets

The United States has extended sanctions exemptions covering Lukoil’s Bulgarian businesses until April 24, 2027. The measure provides additional time for operations at the Burgas refinery and related fuel businesses while the Russian group seeks buyers for international assets. The US Treasury’s Office of Foreign Assets Control issued General License 130B, replacing an earlier authorisation nearing expiry.

The exemption applies to specified transactions involving Lukoil’s Bulgarian subsidiaries, including refinery operations and fuel distribution. It also covers supplies to aviation and maritime customers. A separate General License 128D permits certain transactions involving Lukoil-branded petrol stations outside Russia.

Scope of exemptions and limits under existing restrictions

The US action is described as limited exemptions rather than broader sanctions relief. Transactions involving other sanctioned entities or activities prohibited under existing US restrictions remain covered by those measures. This means the authorisations do not remove all compliance constraints affecting related dealings.

The extension is linked to Bulgaria’s special regulatory framework for Lukoil’s domestic assets. The framework includes provisions allowing a sale without the Russian owner’s consent. It also reflects changes that expanded government authority over businesses placed under special administration.

Bulgaria’s special administration and potential arbitration

Former Bulgarian National Revenue Agency chief Rumen Spetsov was appointed special commercial administrator in November 2025. Legislative changes followed that expanded government authority over companies under special administration. Lukoil’s ownership structure has challenged the intervention through its corporate position.

Switzerland-based Litasco, described as the direct owner of the Bulgarian subsidiaries and wholly owned by Lukoil, has warned it could pursue international arbitration. The dispute follows US sanctions imposed on Lukoil and Rosneft in October 2025. Lukoil subsequently announced plans to dispose of international assets, though the process has taken longer than initially anticipated.

Burgas refinery remains central asset amid ownership uncertainty

The Burgas refinery is identified as the central asset in the Bulgarian portfolio. The latest US extension reduces immediate risk of operational disruption for refinery and fuel distribution activities. At the same time, it does not resolve the question of who will ultimately control one of Southeast Europe’s strategically important refining and fuel-distribution businesses.

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