In a rapidly shifting landscape for European energy, the future of Russian-owned oil assets across the continent has become a focal point of geopolitical maneuvering, economic anxiety, and legal wrangling. As US-led sanctions against Russia’s oil giants Lukoil and Rosneft tighten, countries from Hungary to Serbia, Bulgaria, and Romania are scrambling to secure their energy supplies, protect their economies, and navigate the complexities of international law and politics.
On December 4, 2025, Hungarian oil and gas company MOL made headlines when it expressed interest in acquiring the international assets of Lukoil, Russia’s second-largest oil producer, which is now under stringent US sanctions. According to Reuters, MOL’s ambitions extend not just to Lukoil’s European oil refineries and gas stations, but also to stakes in production assets in Kazakhstan and Azerbaijan. The company’s intentions were reportedly discussed by Hungary’s Prime Minister Viktor Orbán and US President Donald Trump during a meeting in November, underscoring the high-level diplomatic stakes involved.
Hungary, heavily dependent on Russian energy, has received an annual US sanctions waiver to continue using Russian oil and gas. This precarious position has motivated Budapest to maintain cordial relations with both Moscow and Washington, a balancing act that has become increasingly difficult as the war in Ukraine drags on and Western sanctions intensify. MOL is also eyeing the acquisition of the Serbian oil refining company NIS, another Russian-owned entity now under US sanctions.
The US Treasury has so far declined to comment on MOL’s overtures, but the context is clear: as the US imposed sanctions on Lukoil and Rosneft in late October, European countries hosting Lukoil assets were forced to confront the possibility of refinery shutdowns and fuel shortages. Several governments have responded with extraordinary measures to avoid such disruptions.
Romania, for instance, approved a regulation in early December enabling the government to take over local assets of companies under international sanctions, specifically targeting Lukoil. As Reuters reported, this decree gives the Romanian government the authority to appoint special administrators for companies whose operations, if disrupted, could threaten the local economy or energy security. Lukoil’s footprint in Romania is significant, operating 320 gas stations, the country’s third largest refinery, and holding exploration rights in part of the Black Sea.
Bulgaria has taken a similar approach. In November, its parliament passed a law allowing the government to assume control of Lukoil’s Neftohim refinery in Burgas—the largest oil refinery in the Balkans—through a special administrator. While not a formal nationalization, the move puts the refinery’s operations under state supervision. The decision came amid fierce debate, with Bulgarian President Rumen Radev warning that the parliamentary vote “undermined the rule of law” and could expose Bulgaria to costly legal battles if Lukoil seeks compensation in international courts. Nevertheless, parliament overrode his veto, prioritizing energy security over legal risks.
These actions are not without precedent. Germany, facing its own energy crisis after Russia halted gas supplies in 2022, nationalized the Russian-owned energy company Uniper to protect its supply and stabilize the market. The German government’s intervention was deemed essential after Uniper incurred massive losses due to skyrocketing market prices and initiated arbitration against Gazprom, ultimately winning the dispute. The German experience looms large over current policy debates in Southeast Europe, where dependence on Russian energy remains acute.
Meanwhile, the US Treasury under President Trump extended a license in early December allowing continued business with Lukoil-branded gas stations outside Russia, despite the sanctions. As reported by Kyiv Post, this waiver authorizes transactions for roughly 2,000 Lukoil stations across Europe, Central Asia, the Middle East, and the Americas until the end of April 2026. While some Western diplomats have questioned whether these exemptions dilute the impact of sanctions, others argue they help prevent fuel shortages and economic turmoil in affected countries. For example, Bulgaria temporarily restricted petroleum exports to safeguard its domestic market after sanctions were announced.
For its part, Lukoil has pushed back against what it sees as government overreach. In a statement cited by The Moscow Times, the company reserved "the right to seek judicial remedies to protect its rights and legitimate interests in the event of their violation." Russian President Vladimir Putin, during a December visit to India, openly criticized US sanctions, calling into question their legitimacy and pointing to ongoing US purchases of Russian nuclear fuel as evidence of double standards.
Serbia, however, has found itself in a particularly precarious situation. On December 2, President Aleksandar Vučić announced that the United States had denied Serbia an operating license for its Russian-owned Pančevo oil refinery, effectively forcing the facility to halt operations and threatening the country’s fuel supply. "We expected to receive a license from the US government to continue supplying oil to our refinery in Pančevo. We did not receive a positive decision," Vučić said, expressing both disappointment and surprise. With US sanctions on NIS (the Petroleum Industry of Serbia) taking effect in October, the refinery now faces daily losses of €370,000 and has been granted permission to shut down 54 days after sanctions commenced.
Serbia’s energy minister has been tasked with informing NIS of the impending closure, and the government is bracing for broader economic fallout. The National Bank of Serbia and commercial banks risk secondary US sanctions if they conduct transactions with NIS, a scenario Vučić warned would be "a catastrophe for our investment rating and for everything else." The crisis, he emphasized, extends beyond NIS to threaten the entire Serbian economy.
Despite these challenges, Serbia has stockpiled over 200,000 tonnes of diesel and other fuels, with reserves expected to last until late January 2026. The government has also ordered additional supplies of diesel, kerosene, and gasoline to cushion the blow. However, logistical hurdles remain, with Croatia’s JANAF pipeline blocking oil imports intended for Serbian reserves and signaling broader regional tensions.
Looking ahead, Serbia faces a looming deadline to secure a new gas contract by mid-January; otherwise, it will have to turn to alternative sources. The government has given Russia until January 15 to sell its stake in NIS, after which "the state of Serbia will step in," although the specifics of such intervention remain unclear.
The situation remains fluid, with European governments, energy companies, and international actors all vying to shape the outcome. As sanctions continue to bite and political calculations shift, the fate of Russian oil assets in Europe will serve as a litmus test for the continent’s ability to balance energy security, economic stability, and geopolitical principles in an era of heightened uncertainty.