Financial Supervisory Authority’s comment on Teboil entrepreneurs’ appeal (updated 22.12.2025)

Teboil retailers have today, 4 November 2025, appealed to the Financial Supervisory Authority (FIN-FSA) and the Bank of Finland to secure payment transactions.

The FIN-FSA is monitoring the activities of its supervised entities with regard to measures resulting from the sanctions in question.

The FIN-FSA will also continue to cooperate closely with other authorities to find possible solutions.

At this stage, the FIN-FSA has nothing further to add to the supervision release (in Finnish) published regarding the matter on 23 October 2025.

22 December Update: The United States sanctions authority (OFAC) has, by its decision of 4 December 2025, extended the general license (“GL 128B”) granted to Lukoil International GmbH (“LIG”) and entities in which it owns, directly or indirectly, a 50% or greater interest, until 29 April 2026.

In addition, OFAC has published FAQ 1225 clarifying the scope of application of GL 128B. In this context, OFAC states that “non-U.S. persons generally do not risk exposure to U.S. sanctions under Executive Order 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128B and GL 131A. Similarly, non-U.S. persons may rely upon GL 128B and GL 131A regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128B and GL 131A, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.”

The Financial Supervisory Authority recommends that supervised entities take note of OFAC’s newly published General License 128B and the related additional interpretation FAQ 1225.

17 November Update: The Office of Foreign Assets Control’s new exemption decision General License 128A appears to be worded similarly to the previous decision 128, with the only significant difference being the extension of the deadline to December 13. Therefore, there is no need for the FIN-FSA to make any new statement differing from that which we have previously communicated.

4 November Update: There publicly arose the mistaken understanding that the FIN-FSA would not allow through payments made to Teboil entrepreneurs. The situation described by Teboil entrepreneurs is due, however, to sanctions imposed by the United States over which the FIN-FSA has no competence. The role of the FIN-FSA, moreover, does not include stopping payments or controlling financial transactions of any kind, but ensuring supervised entities, such as banks, comply with the sanctions binding on Finland.