On May 28, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 131F (Lukoil GL 131F), replacing General License No. 131E and extending the authorization through 12:01 a.m. EDT on June 27, 2026. The license continues to authorize negotiations and the entry into contingent contracts for the sale of Lukoil International GmbH (LIG), the Austrian holding company through which PJSC Lukoil manages its foreign asset portfolio. OFAC simultaneously updated FAQ 1224 and FAQ 1225 to replace references to GL 131E with references to Lukoil GL 131F.

This is the sixth renewal in the Series 131 sequence. The substantive terms of the authorization are unchanged; only the expiration date has moved. What that pattern signals and what it means for parties with exposure to LIG assets is the subject of this article.

What Is Lukoil GL 131F, and Why It Was Issued

On October 22, 2025, OFAC designated PJSC Lukoil to the Specially Designated Nationals and Blocked Persons List (SDN List) under Executive Order 14024, which targets persons supporting Russia’s ability to finance its war in Ukraine. On December 4, 2025, LIG and its subsidiaries followed.

SDN designation meant full blocking: any transaction involving Lukoil, LIG, or their subsidiaries required a separate OFAC specific license. That created an immediate practical problem. Lukoil operates an extensive network of foreign assets: retail fuel stations, refining facilities, and trading entities across Europe and beyond that serve ordinary consumers with no connection to the Russian war effort.

OFAC’s response was a two-track framework. The Series 128 general licenses (currently GL 128C) address a narrow category: the maintenance and wind-down of LIG’s retail fuel stations outside Russia, with authorization running through October 29, 2026. The Series 131 general licenses address something broader: facilitating the outright sale of Lukoil’s foreign asset portfolio, a transaction that would permanently sever LIG from its Russian parent.

The Series 131 Timeline: From the First License to GL 131F

Series 131 was initially structured as a short-horizon instrument. Each successive renewal added a few weeks, apparently just enough time, in OFAC’s assessment, to allow negotiations to conclude. In practice, those negotiations have now continued for over six months.

• GL 131 (November 14, 2025): initial authorization through December 13, 2025 (29 days).
• GL 131A (December 10, 2025): extended through January 17, 2026 (38 days).
• GL 131B (January 14, 2026): extended through February 28, 2026 (42 days).
• GL 131C (February 26, 2026): extended through April 1, 2026 (32 days).
• GL 131D (March 30, 2026): extended through May 1, 2026 (32 days).
• GL 131E (April 29, 2026): extended through May 30, 2026 (30 days).
• GL 131F (May 28, 2026): extended through June 27, 2026 (28 days).

In each instance, the new license is issued on the final day of the prior one or the day before, ensuring no gap in authorization. That continuity is deliberate, but it does not, on its own, indicate that a deal is imminent.

What Changed in GL 131F Compared to GL 131E

In substance, nothing. Lukoil GL 131F reproduces the operative text of GL 131E without modification: the same authorized activities, the same conditions, the same exclusions. The sole change is the expiration date.

This is a straightforward technical renewal. OFAC is not expanding or narrowing the scope of what is permitted; it is extending the runway for negotiations already underway. FAQ 1224 and FAQ 1225 were updated in parallel, with references to GL 131E replaced by references to Lukoil GL 131F. The substantive guidance in both FAQs is unchanged.

What GL 131F Authorizes: The Two Core Categories

Lukoil GL 131F covers two distinct categories of authorized activity, carried forward unchanged from earlier versions of the license.

Negotiations and contingent contracts for the sale of LIG.

Parties may negotiate with Lukoil and LIG regarding the terms of a sale, disposition, or transfer of LIG or any entity in which LIG holds, directly or indirectly, a 50 percent or greater interest. This includes:

• negotiating the terms of definitive agreements;
• conducting financial, legal, and operational due diligence, including engaging outside advisors and counsel;
• entering into contingent contracts, provided that performance is expressly conditioned on receipt of a separate OFAC authorization.

Maintenance and wind-down of LIG operations.

Transactions ordinarily incident and necessary to the ongoing operations or wind-down of LIG entities are authorized, including:

• fuel and lubricant supply;
• lease and insurance payments;
• property maintenance and environmental services;
• employee compensation, benefits, and severance;
• information technology services;
• payments to government authorities, suppliers, landlords, creditors, and counterparties;
• preservation of previously created property.

Financial institutions and payment processors may debit and credit LIG entity accounts to facilitate authorized transactions. One condition applies across both categories: no funds may be transferred to any person or account located in Russia.

What GL 131F Does Not Authorize

Lukoil GL 131F does not authorize the actual consummation of a sale: no transfer, assignment, or disposition of LIG assets or equity interests. Any contract entered into under GL 131F must expressly condition its performance on receipt of a separate OFAC license. That license would be the subject of a specific license application evaluated against the criteria set out in FAQ 1224.

The license also does not extend to transactions involving blocked persons other than the LIG entities identified in paragraph (a) of the license, unless separately authorized.

Updated FAQ 1224 and FAQ 1225: OFAC’s Clarifications

FAQ 1224 sets out the conditions OFAC will apply when evaluating a specific license application to consummate the LIG sale. OFAC’s position has been consistent since the FAQ was first published:

• the transaction must fully sever LIG from Lukoil;
• any proceeds owed to Lukoil must be blocked in a U.S.-jurisdiction account pending sanctions relief;
• the deal must not confer undue benefit on Lukoil, including through upfront payments, commodity swaps, or equity arrangements;
• purchasers of LIG assets will be required to seek OFAC authorization before any subsequent disposition of material LIG assets.

FAQ 1225 draws the line between GL 128C and Lukoil GL 131F. GL 128C is a narrow instrument: it covers only LIG’s retail fuel stations outside Russia and runs through October 29, 2026. Lukoil GL 131F is broader in both scope and purpose: it covers all LIG entities and is directed at facilitating a complete exit from Lukoil’s foreign portfolio.

Both FAQs confirm that non-Russian persons generally do not face sanctions exposure under E.O. 14024 for engaging in transactions with blocked persons that are broadly authorized for U.S. persons, provided the conditions of the applicable license are satisfied.

What Comes After GL 131F: Three Scenarios

The issuance of Lukoil GL 131F signals continuation, not resolution. At this stage, three paths are plausible.

Scenario 1: A contingent contract and a specific license application. If the parties reach an agreement on material terms, they may execute a contingent contract under Lukoil GL 131F and submit a specific license application to OFAC for authorization to close. OFAC would evaluate the application against the criteria in FAQ 1224.

Scenario 2: Another renewal. If negotiations remain active but inconclusive, OFAC may issue GL 131G. The Series 131 record shows that OFAC is willing to extend the authorization as many times as the process requires, so long as it is satisfied that negotiations are being conducted in good faith.

Scenario 3: Revocation. GL 131F expressly preserves OFAC’s authority to revoke the license at any time, including if OFAC concludes that Lukoil or LIG is not engaging in negotiations in good faith. This is a pressure mechanism, not a formality.

Notably, none of the issuances in the Series 131 sequence has been accompanied by any announcement of a concluded deal. There is no public record of where negotiations stand. The pattern of repeated renewals suggests that OFAC views the process as genuine. Otherwise, the license would have been allowed to lapse rather than extended.

For parties with exposure to LIG assets or an interest in their acquisition, Lukoil GL 131F preserves the legal space for continued negotiations and ordinary operations. Whether the current authorization period will prove to be the last is a question that should become clear within the coming weeks.