Several energy-sector actors have been granted exemptions from the sanctions on purchasing Russian oil and gas, yet Hungary does not appear on the list. According to the Hungarian government, the Trump–Orbán agreement guarantees the exemption, but no written authorisation has been issued so far, and the sanctions will enter into force shortly.

The United States issued four temporary exemptions from the sanctions imposed on Rosneft and Lukoil on 14 November in order to prevent significant disruptions in supply, Portfolio reports.

According to the justification provided by OFAC, which operates under the US Department of the Treasury, the countries, energy-sector actors and institutions listed would have suffered major and serious losses as a result of the measures against the two oil companies. Hungary, however — oddly enough — is not included.

The exemptions are only short-term

The first exemption was granted to Kazakhstan, ensuring the uninterrupted operation of the CPC oil pipeline, the Tengiz oilfield and the Karachaganak site. Only the sale of ownership stakes and transactions unrelated to day-to-day operations remain prohibited.

In second place on the list are Lukoil’s foreign filling stations. The international network encompasses more than five thousand stations, making it essential that operations and procurement of supplies remain possible until mid-December.

Lukoil’s Bulgarian subsidiaries — such as the Burgas refinery, as well as filling stations and kerosene processing facilities — have also been exempted and may operate freely until the end of April 2026. In addition, preparatory procedures required for the sale or restructuring of the European headquarters have been authorised.

As is clear, each exemption is subject to strict time limits — in some cases barely more than a month — indicating that the United States is seeking to minimise the scope for Russian companies while preventing supply disruptions in the regions concerned.

lukoil russia gas stations refinery hungary bulgaria sanctions
Illustration: depositphotos.com

Diverging positions between the two foreign ministers

Hungary does not appear on the latest list at all. Nevertheless, the Hungarian government claims that on 7 November Viktor Orbán received a verbal promise from Donald Trump at the White House that Hungary would be exempt from the sanctions.

However, as reported by 24.hu, there is a significant discrepancy between US and Hungarian statements. Péter Szijjártó, Minister of Foreign Affairs and Trade, asserts that the agreement guarantees Hungary’s exemption until the end of the two leaders’ terms in office, and that putting it in writing is merely a technical formality.

In contrast, US Secretary of State Marco Rubio states that the exemption would apply for at most one year, and that only temporary authorisation can be granted for certain pipelines. Gergely Gulyás has said that Szijjártó will formally contact Rubio in order to clarify the misunderstandings, while Viktor Orbán has commented that ultimately “the boss” — that is, Trump — will decide the matter.

Only OFAC can make a concrete decision

The main source of uncertainty is that actual exemption can only be granted through a written licence issued by OFAC. Hungary must apply for this separately, and under US practice such licences are reviewed annually and therefore are usually granted for only one year, regardless of the political objectives behind them.

All this means that Hungary must continue to wait for the official document that would clarify the conditions and the time limits under which it may receive an exemption.

However, the sanctions are set to enter into force on 21 November, meaning the deadline for a decision is approaching rapidly, while Hungary’s situation remains unresolved.