On April 17, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 134B (GL 134B), to replace GL 134A, which had expired six days earlier on April 11. The new iteration of the OFAC general license for Russian oil follows a familiar template: it authorizes the transactions needed to sell, deliver, and offload Russian crude and petroleum products loaded onto a vessel on or before April 17, 2026. The license expires on May 16, 2026.

What changed in GL 134B compared to GL 134A

GL 134B is a near-verbatim reissue of GL 134A. Only two dates have moved: the loading cutoff has advanced from March 12 to April 17, 2026, and the expiration date has been pushed out to May 16, 2026. Everything else is identical.

Paragraph (a) still authorizes the same range of vessel-side operations: safe docking and mooring, crew medical care, emergency repairs, environmental response, ship management, bunkering, pilotage, registration, insurance, classification, and salvage. The authorization continues to reach blocked vessels, including those on the SDN List.

Paragraph (b) carries forward the jurisdictional carve-outs introduced in GL 134A. The license does not authorize any transaction involving persons located in Iran, North Korea, Cuba, the Covered Regions of Ukraine (under E.O. 14065), or Crimea (under E.O. 13685), nor does it reach entities owned, controlled, or jointly held by such persons.

The six-day gap between GL 134A and GL 134B

The more interesting question is not that GL 134B issued, but how. GL 134A expired on April 11; GL 134B took effect on April 17. For six calendar days, no general license in the 134 series was in force.

That gap has operational consequences. Cargoes loaded between April 11 and 16 were never within GL 134A in the first place (its loading cutoff was March 12) and sat outside any authorization until GL 134B appeared. A separate risk layer covers the April 11 to 16 window specifically: even cargoes that fell within GL 134A by loading date could not rely on the expired license for offloading or related services during those six days, and GL 134B was not yet in force to cover them.

OFAC has offered no public explanation. Several readings are plausible. One is administrative: OFAC may have assumed the market would hold cargoes until the successor license issued. Another is tactical: the delay served as a quiet reminder that each renewal of the OFAC general license for Russian oil is discretionary, not automatic. A third is political: the Trump administration’s unsettled posture on Russia sanctions may have slowed the paperwork, with the gap as a byproduct rather than a signal.

Whichever reading is right, the operational takeaway is the same. Treating a chain of successor general licenses as a single continuous authorization, without planning for gaps between them, is a compliance posture with real downside.

Third installment in the series: from exemption to cycle

GL 134B is the third document in this line. GL 134 (March 12) dropped the India-specific geography of GL 133 in favor of universal scope; GL 134A (March 19) added jurisdictional carve-outs without touching the core dates; GL 134B (April 17) now pushes the loading and expiration dates forward on what looks like a 30-day cycle.

Treasury Secretary Scott Bessent recently called the OFAC general license for Russian oil a “deliberately short-term measure.” On current form, it is moving toward a standing feature of the regime, refreshed roughly every month, with the loading cutoff advanced by four to five weeks each time.

Practically, this is sanctions management in real time. The underlying prohibition remains in place: E.O. 14024 is in force, 31 CFR part 587 has not been amended, secondary sanctions exposure for third-country actors has not been lifted, and the G7 price cap continues to apply. Over that static framework, OFAC has layered a rolling authorization that changes each month and has to be read anew each time.

For compliance teams, the result is a two-tier regulatory picture: a stable base of prohibitions paired with a moving window of permissions.

Geopolitical context: Iran, Ukraine, oil prices

The conditions that prompted the first license in the series have not gone away. Hostilities with Iran continue, global crude trades above $90 per barrel, and Indian and European buyers still rely on supply routes that historically passed through the Strait of Hormuz. None of that has eased enough for Washington to close the oil safety valve.

In parallel, talks on a Ukraine settlement are moving forward. The jurisdictional carve-outs introduced in GL 134A and carried into GL 134B (the Covered Regions of Ukraine and Crimea) function as negotiating leverage: they ensure the current oil relief does not inadvertently reach territories whose status is still contested internationally. That preserves the Trump administration’s room to maneuver in whatever package it eventually puts together on Ukraine.

If the Ukraine track reaches closure, the next license (presumably GL 134C) could depart meaningfully from the template. The loading cutoff might disappear, the scope of authorized services might expand, or the price-cap terms might soften. For the time being, the OFAC general license for Russian oil is being renewed by inertia, copying its predecessor with only the dates adjusted.

Practical compliance takeaways

For companies active in international trade, shipping, vessel finance, and related services, GL 134B triggers several near-term steps.

First, update the reference materials. Every internal memo, compliance procedure, and contract clause that cites GL 134A needs to be moved to GL 134B now. Work performed under documents that point to an expired general license carries no sanctions safe harbor.

Second, paper the status of assets during the April 11 to 17 window. If cargoes or vessels were mid-operation under GL 134A, the question is whether those operations closed out before 12:01 a.m. EDT on April 11. Anything that did not requires a separate legal review.

Third, keep broader counterparty screening in place. GL 134B’s carve-outs match GL 134A’s: Iran, North Korea, Cuba, the Covered Regions of Ukraine, and Crimea. Screening across subcontractor chains (ship managers, P&I clubs, tug operators) needs to cover each of those.

Fourth, plan for the next renewal. With the OFAC general license for Russian oil now refreshed twice within a single 134 series, mid-May 2026 is the realistic window for another iteration, likely with a loading cutoff around May 15 or 16. Supply planning past May 16, 2026, should rest on that expectation, while understanding that no renewal is guaranteed.

Conclusion

At first read, GL 134B looks like housekeeping: the same permissions, the same exclusions, new dates. That is true on the face of it. But stacked with GL 134 and GL 134A, this third iteration converts what was pitched as a short-term carve-out into a renewable monthly regime.

For businesses, that produces two parallel requirements: keep real-time watch on each new issuance and build the gap between issuances into the plan. An expiring license does not guarantee a successor is ready on day one. Treating the OFAC general license for Russian oil as a continuous authorization, rather than a sequence of discrete 30-day windows separated by potential gaps, carries meaningful sanctions risk.