OFSI permits wind-down of Zarubezhneft transactions until 21 November

Under Russia-regime General Licence INT/2026/11080040, a Person who is a party to transactions involving the DP may wind down or divest from those transactions, including by closing out positionsPublishing. The DP is ZARUBEZHNEFT JSC, and each of its Subsidiaries counts as a DP tooPublishing, so the permission reaches transactions involving entities Zarubezhneft owns or controls as well as Zarubezhneft itself. The licence took effect on 8 October 2026Publishing and expires at 23:59 on 21 November 2026Publishing, so counterparties with Zarubezhneft exposure must complete their exit by that time.

The permission is available to any Person who is a party to transactions involving the DP. A Person means an individual or a body of persons corporate or unincorporate, but not a Designated Person. The DP means ZARUBEZHNEFT JSC, and each Subsidiary counts as a DP as well: a Subsidiary is any entity incorporated anywhere in the world owned or controlled, directly or indirectly, by ZARUBEZHNEFT JSC within the meaning of regulation 7 of the Russia Regulations. Ownership or control on that test turns on holding more than half the shares or voting rights, holding the right to appoint or remove a majority of the board, or otherwise being able in most cases or in significant respects to have the entity's affairs conducted in accordance with the holder's wishes. Counterparties should therefore map not only direct dealings with Zarubezhneft itself but also dealings with entities it owns or controls, since those fall inside the licence's scope as well.

What the licence authorises is the winding down of, or divestment from, any transactions involving the DP to which the Person using the licence is a party, including the closing out of any positions. Beyond the Person itself, a Relevant UK Institution or the DP may carry out any activity reasonably necessary to effect the wind-down or divestment. Relevant UK Institutions are UK-regulated conduits: firms with Part 4A permission under the Financial Services and Markets Act 2000, firms authorised or registered under the Payment Services Regulations 2017 or the Electronic Money Regulations 2011, recognised clearing houses, central counterparties and central securities depositories (including third-country ones), and operators of, and service providers to, recognised payment systems. Acts that would otherwise breach the asset-freeze prohibitions in regulations 11 to 15 of the Russia Regulations are exempt to the extent required to give effect to these permissions. Those prohibitions cover dealing with funds or economic resources owned, held or controlled by a designated person, and making funds or economic resources available to or for the benefit of one.

Three limits matter in practice. First, anyone undertaking an activity the licence permits or purports to permit — the DP, the Person or the Relevant UK Institution — must keep accurate, complete and readable records of that activity, on paper or electronically, for a minimum of six years. Second, the licence authorises nothing beyond its own permissions: any act that would breach another part of the Russia Regulations remains prohibited unless a separate licence covers it. Third, HM Treasury may vary, revoke or suspend the licence at any time, so reliance on it should be checked against its current status before each step of an exit.

OFSI issued the licence under regulation 64 of The Russia (Sanctions) (EU Exit) Regulations 2019, and the OFSI General Licences collection page added a row for it dated 8 October 2026. Counterparties intending to use the licence should work from the full licence text for the complete definitions, permissions and usage requirements rather than relying on the publication notice summary. Legal basis: regulation 64 of The Russia (Sanctions) (EU Exit) Regulations 2019.