What Changed on June 11, 2026

On June 11, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 115D, “Authorizing Certain Transactions Related to Civil Nuclear Energy.” It replaced and superseded General License 115C, which had been in force since December 2025. The substance is unchanged, but the authorization now runs six months longer: transactions tied to civil nuclear energy are permitted through December 18, 2026.

U.S. civil nuclear energy sanctions retain their earlier logic: this is not a lifting of restrictions but an extension of a narrow carve-out. For market participants, that extension means predictability through year-end: projects that rely on the authorization can plan payments and shipments without fearing that the license will lapse mid-summer.

What OFAC General License 115D Authorizes

Civil nuclear energy sanctions are built around a targeted exception rather than a general permission. OFAC General License 115D authorizes transactions that would otherwise be prohibited by Executive Order 14024, provided they relate to civil nuclear energy and involve a defined set of Russian financial institutions.

A key feature is that a general license operates automatically. To carry out a covered transaction, you do not need to seek separate approval from OFAC; the deal has to fit the terms of the license. That is what distinguishes an OFAC general license from a specific license, which an applicant requests individually for a particular transaction.

Which Entities the License Covers

The authorization reaches transactions involving the institutions named in the license, among them:

• Gazprombank;
• Vnesheconombank (VEB);
• Otkritie;
• Sovcombank;
• Sberbank;
• VTB;
• Alfa-Bank;
• Rosbank;
• Bank Zenit;
• Bank Saint-Petersburg;
• the National Clearing Center (NCC);
• any entity owned 50 percent or more, directly or indirectly, by one or more of the above; and
• the Central Bank of the Russian Federation.

The list captures nearly every systemically important Russian bank through which energy-project settlements pass. That is why civil nuclear energy sanctions, in practice, come down to a single question: how to move a payment through these institutions without breaching an adjacent prohibition.

What Counts as Civil Nuclear Energy

The license defines transactions “related to civil nuclear energy” narrowly: dealings undertaken solely to maintain or support civil nuclear projects initiated before November 21, 2024.

Two practical points follow. First, the authorization does not cover new projects launched after that date; a different regime applies to them. Second, the transaction must genuinely serve an existing project: fuel supply, maintenance, transport, or settlements under live contracts. Step outside that purpose, and the reference to the license no longer holds.

Why the word “solely” matters is clear from a real example. As reported in the press, back in 2022 (before Gazprombank was designated) billions of dollars moved through a scheme built around a nuclear plant under construction in Turkey. On paper, it was payment for the nuclear project, but, according to U.S. investigators, part of the money served a different purpose: building a dollar reserve for interests unconnected to nuclear energy. It is precisely this kind of mixed-purpose transfer that the license’s definition screens out: the moment a payment stops being solely the support of a nuclear project, the reference to the authorization fails.

That same narrowness explains why a general license cannot be used as a tool to release funds that have already been seized. Around $2 billion from that scheme ended up frozen at a U.S. bank; not as ordinary sanctions-blocked money, but on suspicion of sanctions evasion, money laundering, and bank fraud. A general license authorizes future, good-faith transactions; it does not retroactively cleanse funds the government treats as illegal proceeds. An attempt to fit such money under the civil nuclear carve-out, therefore, goes nowhere: the license is deliberately built to cover the servicing of genuine projects, not to serve as a channel for moving contested assets.

What the License Does Not Authorize

This is where most of the risk sits. General License 115D expressly does not authorize:

• opening or maintaining a correspondent or payable-through account for any entity subject to Directive 2 (the prohibition on correspondent accounts and on processing transactions for certain foreign financial institutions);
• any debit to a U.S. bank account of the Central Bank of Russia, the National Wealth Fund, or the Ministry of Finance; or
• any other transaction prohibited by 31 CFR Part 587, including dealings with blocked persons not named in the license.

In short, the license opens a narrow corridor but leaves the surrounding prohibitions intact. Cross any of them, and a nominally “energy” transaction becomes a sanctions violation.

How to Route a Payment Around Directive 2

The most common practical question is how to actually move an authorized payment when the receiving bank is restricted on correspondent accounts. OFAC’s updated guidance answers it: a U.S. bank cannot maintain a correspondent account for a Directive 2 institution, so the payment must not travel directly; it has to pass through a non-sanctioned, non-U.S. intermediary bank.

The chain looks like this: funds move from the originator, through its bank and a U.S. correspondent bank, to a non-sanctioned, non-U.S. intermediary bank, which in turn passes them to the target bank (the institution subject to Directive 2), which then credits its own customer – the beneficiary. What is prohibited is precisely the direct link from a U.S. correspondent to the target bank; the intermediary bank is inserted specifically to avoid it. The presence of a U.S. correspondent is not itself barred: Directive 2 does not remove U.S. banks from the payment flow altogether; it only prevents them from maintaining a correspondent account directly for a bank subject to Directive 2. This is where civil nuclear energy sanctions are won or lost in practice; the authorization exists, but a single error in the payment route turns a lawful transaction into a prohibited one.

When a Bank Refuses a Payment Despite the License

Banks often reject even authorized payments, out of caution or because of automated filters. OFAC’s updated guidance acknowledges this directly and suggests two steps: first, check the status of the payment with the bank, and, if needed, contact the OFAC Compliance Hotline.

A refusal is not a dead end – it is a prompt to document, on paper, that the transaction fits the terms of the license. A well-prepared explanatory letter to the bank, citing the license conditions and describing the payment structure, will often clear a block that arose from over-caution rather than any real prohibition.

How a Sanctions Lawyer Can Help

Civil nuclear energy sanctions are an area where authorization and prohibition are separated by a thin line: a substantively correct transaction can still be blocked by the wrong payment route or by drifting outside the definition of civil nuclear energy. Our practice focuses specifically on U.S. sanctions law: we assess whether a given transaction falls under an OFAC general license, build a compliant payment structure, and prepare the supporting rationale for the bank. That approach lets clients use the authorization as intended and reduces the risk of a refusal.