The Ministry of Foreign Affairs of Romania has opened for public debate an emergency ordinance project that allows the Romanian Government to establish an extended surveillance mechanism over Lukoil’s assets, affected by the sanctions imposed by the USA.
According to the project, extended surveillance stipulates that, in the case of unilateral sanctions adopted by other states, which are not mandatory for Romania, but which produce effects on Romanian territory, the Romanian Government can adopt, ex officio, with the approval of the Supreme Defense Council of the Country, a Government decision, by which:
a) it acknowledges the significant economic impact of the effects produced on the Romanian economy by these sanctions;
b) it decides to establish extended surveillance and designates a representative to exercise the role of supervisor, establishing his rights, obligations, and duties, in accordance with this ordinance;
c) it determines the legal entity subject to extended surveillance;
d) it establishes any elements necessary for the efficient implementation of extended surveillance, including the identification of persons and/or entities subject to unilateral sanctions adopted by other states and with which the legal entity subject to extended surveillance cannot conduct commercial/contractual operations.
The designated supervisor has the following main rights:
a) to participate in the general meetings of shareholders, associates, the board of directors, and other similar meetings regarding the management of the legal entity, as an observer;
b) to have access to all locations where the legal entity conducts its activity;
c) to have access to all documents received by the legal entity or emanating from it, namely financial-accounting, legal, and other documents related to economic activity, especially documents concerning any transaction or external payment of the legal entity;
d) to be remunerated for the activity carried out, from the funds of the legal entities, with an indemnity at the maximum level established for board members, in the case of companies provided for in art. 2 lit. c) and d) of Law no. 31/1990, republished, with subsequent amendments and completions, or at the maximum level of the salary of persons in management positions, in the case of companies provided for in art. 2 lit. a), b) and e) of the same law, but not less than 10,000 lei gross.
The designated supervisor has the following main obligations:
a) to approve all transactions and external payments of the supervised legal entity;
b) to monitor the activity of the legal entity in order to identify any reasonable indications regarding the conduct of any operations with designated persons and/or entities, which are subject to unilateral sanctions adopted by other states, which are not mandatory for Romania;
c) to request the point of view of the legal entity within 24 hours of the findings made according to lit. b); d) to immediately inform the Government about the findings made, as well as the point of view presented by the legal entity;
e) to prepare a monthly report to the Government on the activity of the legal entity, based on the monitoring activity;
f) to maintain commercial and fiscal secrecy and to ensure the confidentiality of personal data in the performance of his duties;
g) to make the necessary efforts to ensure that the supervised legal entity complies with the international sanctions mandatory for Romania.
A few days ago, energy expert Dumitru Chisăliță, president of the Intelligent Energy Association (AEI), said that there are Romanian companies that have the capacity to take over the entire customer segment owned by Lukoil for the distribution of petroleum products in Romania, without affecting current exports, through the direct import of gasoline and diesel, if the storage capacities of the Oil Terminal currently used by Lukoil are made available.
“There is also the possibility of a temporary takeover of Lukoil by the Romanian state, through a special administrator, without it being a definitive takeover, and the management of the company under the coordination of the Romanian state, so that the imported oil continues to be processed at Petrotel in Romania and to ensure the coverage of the Lukoil customer segment currently in existence.
The takeover or control of the state over the Lukoil company involves financial risks – possible claims for compensation, budgetary effort for the administration of the company, but especially the issue of the state’s competence in managing refineries and the distribution network, as well as the possibility of developing corruption and the leeching of the company”, the energy expert opined.
The expert, however, warned that these variants will come with higher costs, also due to some contracts made in a hurry, but ensuring the existence in sufficient quantities of fuels at the pump.
“For Romania, the most important objective in the Lukoil context is the rapid decision-making regarding the company, maintaining normal fuel supply flows and avoiding panic at the population level. Artificial congestion at gas stations can create a false increase in demand, can disrupt distribution and can lead to temporary price increases, even if there is no real crisis.
As long as the authorities do not communicate through clichés, but will conduct a correct, sincere and professional dialogue with the population, and the population fuels normally, the market remains stable, stocks can be ensured, and prices will not explode”, said the energy expert.
Lukoil is under US sanctions
US sanctions came into effect on Friday, starting at 7:00 PM, regarding the Petrotel – Lukoil refinery. In the case of gas stations, the sanctions apply from December 13.
The sanctions, announced on October 22, 2025, aim to restrict the financing of the Russian economy and the “war machinery of the Kremlin”. The US Treasury Department specified that the measures extend to the subsidiaries and partners of these companies, prohibiting American entities and their allies from conducting commercial or financial transactions with Lukoil.
The Office of Foreign Assets Control (OFAC) set the deadline of November 21, 2025, for the closure or sale of international assets owned by the Russian company, under the risk of additional sanctions.
On November 14, 2025, OFAC extended the deadline to December 13, 2025. “GL 131 also authorizes, until December 13, 2025, the usual and necessary transactions for maintaining or terminating operations, contracts or other agreements of LIG entities. This includes transactions that are necessary for the execution of pre-existing agreements, provided that these transactions are in accordance with previously established practices and support pre-existing projects or operations. Such activities could also include payments to employees, suppliers, owners, creditors, and partners; the preservation and maintenance of pre-existing corporate properties; or activities associated with maintaining pre-existing capital investments. However, any payment made, directly or indirectly, to LIG entities or any other blocked person must be made into a blocked account (…) unless separately authorized by OFAC”, the American office added.
Lukoil later confirmed that it had begun the process of identifying buyers for overseas assets and announced its intention to sell its entire international network, including refineries in Romania and Bulgaria.
The former CEO of the company, quoted by Politico, estimated that the measure could reduce Lukoil’s revenues by up to 30%, by selling three refineries and about half of the 5,000 gas stations operated globally.