Lukoil Sanctions
Sanctions related to Russias invasion of Ukraine are based mainly on national emergency authorities granted the office of the President in the National Emergencies Act NEA. 1621 et seq and International Emergency Economic Powers Act IEEPA.
Adam Tooze Adam Tooze Bond Issue Oil And Gas Emergency
Following Secretary Lews determination Treasury has imposed sanctions that prohibit transactions by US.

Lukoil sanctions. Persons or within the United States involving new debt of greater than 30 days maturity.
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