On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a sweeping set of actions to further reduce Russian revenues from energy, including blocking two major Russian oil producers, Gazprom Neft and Surgutneftegas, and imposing sanctions on a very significant number of oil-carrying vessels, opaque traders of Russian oil located in jurisdictions like Hong Kong and the UAE, Russia-based oilfield service providers, and Russian energy officials.  The U.S. Department of State also took steps to block two active liquefied natural gas projects, a large Russian oil project, and third-country entities supporting Russia’s energy exports. Lastly, the United Kingdom also joined the U.S. in sanctioning Gazprom Neft and Surgutneftegas – which, coupled with the joint Memorandum of Understanding issued by OFAC and OFSI on January 13, is a testament to the increased cooperation between the U.S. and UK authorities. Although there are wind-downs in place for most of these entities, this round of designations is likely to cause major disruptions in the market. We summarize the new restrictions in turn below: