Following the policy of consistently escalating the sanctions pressure, the US enforced on 10 January 2025 an unprecedented package of sanctions against the Russian energy sector.

The principal difference of the new package from the relatively recent ones is that in many cases, inclusion in the SDN List is made in the framework of two sanctions programmes at once - E.O. 14024 and E.O. 13662, making cancellation much more difficult for the new administration.

More information about the introduced restrictions can be found in the alert on sanctions law practice by VERBA LEGAL.