Romania Moves to Assume Lukoil's Black Sea Gas Stake Ahead of US Sanctions

Legislative Amendments Pave Way for State Control

Romania is advancing legislative changes to its Oil Law (Petroleum Law no. 238/2004), enabling the state to assume control of assets held by companies subject to international sanctions. This move specifically targets Lukoil's majority stake in the Trident offshore gas concession in the Black Sea, ahead of the impending US sanctions against the Russian energy giant, scheduled to enter into force on December 13.

The proposed amendments stipulate that if a beneficiary of an oil agreement becomes subject to sanctions binding on Romania, that entity would automatically lose its status as a titleholder. Furthermore, the government would gain the power to unilaterally terminate petroleum agreements on national security grounds when non-EU legal entities are among the owners.

Lukoil's Role in Trident Concession

Lukoil currently holds an 87.5% majority stake in the Trident perimeter (EX-30), with the Romanian state-owned company Romgaz holding the remaining 12.5%. Lukoil initiated exploration activities in the Romanian sector of the Black Sea in 2012, including the Trident and Est Rapsodia (EX-29) blocks. The Lira-1x exploratory well, drilled in the Trident block in 2015, indicated a productive gas bundle with an estimated 30 billion cubic meters of gas. Lukoil's exploration license for the Trident block is set to expire in the first half of 2026.

Implications of US Sanctions and Potential Legal Challenges

The US Department of the Treasury's Office of Foreign Assets Control (OFAC) imposed sanctions on Lukoil and Rosneft in October 2025, with these measures becoming effective on November 21, 2025. These sanctions aim to pressure Russia's energy sector in response to the ongoing conflict in Ukraine.

Romania's preferred scenario is for a Romanian company to acquire Lukoil's stake. If no suitable buyer is found, the stake would be transferred to Romgaz. However, this approach carries potential legal risks for Romania. Lukoil has invested 'several hundred million dollars' in exploration and development in the Trident concession over the past fourteen years. The current draft ordinance does not include a compensation mechanism for Lukoil, which could lead to international litigation.

Broader Energy Security Strategy

This move is part of Romania's broader strategy to enhance its energy sovereignty and reduce its exposure to Russian-controlled assets in critical sectors. The Romanian government approved a decree on December 2, 2025, allowing it to take control of local assets belonging to sanctioned companies if their activities threaten market stability or national energy security. This aligns with similar actions taken by neighboring countries, such as Bulgaria, which passed legislation to take control of Lukoil's refinery. Romgaz is also a key partner in the Neptun Deep project, another significant offshore gas development in the Black Sea, with ambitions to make Romania the European Union's leading natural gas producer by 2027.