On April 14, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published two updated general licenses directly tied to Lukoil sanctions: General License 128C (GL 128C) and General License 130A (GL 130A). OFAC also revised its FAQ 1225 on the same date. The two Lukoil OFAC Licenses replace their predecessors and significantly extend the applicable time horizons: both authorizations run through October 29, 2026, compared to April 29, 2026, for GL 128B and GL 130.

This is far from the first round of Lukoil-related licensing updates in 2026. Earlier this year, we covered the series of extensions to the negotiation window for the sale of Lukoil International GmbH (LIG), as well as the Russian oil licenses GL 134 and GL 134A. The documents issued on April 14 operate on a different level: they do not address the sale of Lukoil’s overseas holding company or the global trade in Russian crude, but rather two specific operational categories — Lukoil retail service stations worldwide and Lukoil’s Bulgarian refining and distribution cluster.

GL 128C: Extended Deadline and Updated Coverage for Retail Service Stations

GL 128C takes effect on April 14, 2026, fully replacing GL 128B, which was issued on December 4, 2025. The scope of authorized activity is unchanged, but the new license has been updated in two respects.

Expiration date. GL 128B was set to expire on April 29, 2026. GL 128C sets a new deadline: October 29, 2026, exactly six months later.

Named entities. GL 128B authorized transactions involving LIG and any entity in which LIG holds, directly or indirectly, a 50 percent or greater interest. GL 128C preserves that formulation but goes a step further, expressly naming two U.S. legal entities: Lukoil North America LLC and Lukoil Americas Corporation. The addition is clarifying rather than expanding; both entities already fell within GL 128B’s 50 Percent Rule coverage. That said, for U.S. counterparties dealing directly with either entity, an express reference in the license text removes any ambiguity and simplifies compliance documentation.

Scope of authorization. GL 128C covers all transactions prohibited by Executive Order 14024 (E.O. 14024), that are ordinarily incident and necessary to purchasing goods and services from LIG Entities, or to maintaining, operating, or winding down physical retail service stations located outside Russia. Blocked accounts of LIG Entities may be used, debited, or credited in connection with these transactions.

Limitations. GL 128C does not cover transactions prohibited by Directive 2 (correspondent and payable-through accounts of certain foreign financial institutions) or Directive 4 (Russia’s Central Bank, National Wealth Fund, and Ministry of Finance) under E.O. 14024. The license also does not authorize transactions with SDN-listed persons other than the LIG Entities described in paragraph (a), and it expressly prohibits any transfer of funds to persons or accounts located in Russia.

GL 130A: The Bulgarian Cluster

GL 130A, also dated April 14, 2026, replaces GL 130, which was originally issued on November 14, 2025. The two licenses are identical in substance: GL 130A simply extends the expiration date from April 29, 2026, to October 29, 2026.

GL 130A authorizes all transactions prohibited by E.O. 14024 involving the following four Bulgarian entities and any entity in which one or more of them hold, directly or indirectly, a 50 percent or greater interest:

• Lukoil Neftohim Burgas JSC (the Burgas refinery — the largest in Bulgaria and on the Balkan Peninsula);
• Lukoil Bulgaria EOOD (retail fuel stations across Bulgaria);
• Lukoil Aviation Bulgaria EOOD (aviation fuel);
• Lukoil Bulgaria Bunker EOOD (marine bunkering).

The phrase “all transactions,” without any reference to wind-down or maintenance-only activities, authorizes full commercial operations for these entities: procurement, sales, financial settlements, and commercial contracts, to the extent such transactions are otherwise prohibited by E.O. 14024. This regime has been in place since GL 130 was first issued in November 2025. GL 130A preserves it in full and carries it through October 29, 2026.

Why Bulgaria specifically? Lukoil’s Bulgarian footprint carries strategic weight. The Lukoil Neftohim Burgas refinery processes a substantial share of the Russian crude reaching Balkan markets and supplies fuel to several EU member states. Bulgaria has separately secured oil sanctions carve-outs at the European level, and GL 130A mirrors that logic within the U.S. regulatory framework: OFAC treats the Bulgarian cluster as a stand-alone authorization rather than folding it into the broader GL 128C regime.

Limitations under GL 130A are narrower than those of GL 128C: the license simply states that it does not cover any other SDN-listed persons under the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR) beyond the four named entities and their subsidiaries, unless separately authorized.

FAQ 1225: Updated to Reflect the New Licenses

FAQ 1225 was originally published on December 4, 2025, and last updated on January 14, 2026. The April 14, 2026, revision is technical: references to GL 128B and GL 131B have been replaced with GL 128C and GL 131D, respectively. The substantive guidance, covering the types of permitted transactions and the applicability of the licenses to non-U.S. persons, remains unchanged.

Worth noting: FAQ 1225 continues to treat GL 128 and GL 131 as a paired framework: one governing the operational activities of retail service stations, the other governing the LIG sale negotiation track. GL 130A is not separately addressed in FAQ 1225; its role in OFAC’s published guidance has yet to be formally defined.

Lukoil OFAC Licenses in Context: What Changes

The Lukoil OFAC Licenses issued on April 14 primarily serve an operational function. The GL 131 series created the conditions for negotiating the sale of Lukoil’s overseas assets; GL 128 and GL 130 ensured that those assets did not go dark while the sale remained pending.

GL 130A extends GL 130 on identical terms: Lukoil’s Bulgarian entities continue to operate under the full commercial authorization granted by OFAC in November 2025. What matters here is the synchronization: both GL 128C and GL 130A expire on October 29, 2026, giving market participants a single planning horizon across Lukoil’s retail and refining operations outside Russia.

The negotiation license GL 131D expires considerably earlier, on May 1, 2026. If OFAC does not issue GL 131E, and if no specific license is granted to authorize the actual LIG sale, the Lukoil OFAC Licenses for operations will remain in force while the negotiation window closes. The two tracks are running in parallel but on different clocks.

Practical Takeaways

Update compliance documentation. GL 128B expired on April 14, 2026. Any internal memoranda, contracts, or bank communications referencing GL 128B must be updated to cite GL 128C. The same applies to GL 130: it has been replaced by GL 130A.

U.S. Lukoil entities. The express naming of Lukoil North America LLC and Lukoil Americas Corporation in GL 128C is significant for their U.S. counterparties. Banks and payment processors maintaining accounts for these entities can rely directly on GL 128C without having to construct a 50 Percent Rule analysis.

Bulgarian operations. GL 130A is substantively identical to GL 130: full commercial authorization for Lukoil Neftohim Burgas JSC, Lukoil Bulgaria EOOD, Lukoil Aviation Bulgaria EOOD, and Lukoil Bulgaria Bunker EOOD has been in place since November 2025 without interruption. GL 130A simply carries that authorization forward to October 29, 2026.

Next review date. Both licenses expire on October 29, 2026. That date will be the next key decision point: either a further extension or a change in Lukoil’s sanctions status as a result of a completed transaction or a broader shift in U.S. sanctions policy.

If your company transacts with Lukoil assets or counterparties outside Russia and needs a legal assessment of how GL 128C or GL 130A applies to your specific situation, we recommend consulting a sanctions attorney.

Conclusion

The Lukoil OFAC Licenses issued on April 14, 2026, do not alter the sanctions regime applied to Lukoil itself, but they meaningfully extend the operational space available to its entities outside Russia. GL 128C carries the retail service station authorization forward by six months and expressly identifies the two U.S. affiliates within the licensed group. GL 130A continues the full commercial authorization for Lukoil’s Bulgarian cluster without any change to its terms.

Both licenses run through October 29, 2026, a synchronized endpoint that will serve as the next key milestone in the evolving sanctions framework governing Lukoil’s international assets.