A new date, and nothing else

On September 18, 2026, the Office of Foreign Assets Control (OFAC) issued a new general license (GL) under the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR), codified at part 587 of title 31 of the Code of Federal Regulations (C.F.R.). OFAC GL 131J replaced GL 131I in its entirety, effective the day it was signed, one day before the earlier authorization would have lapsed.

Read against its predecessor, the new license carries no substantive change. Paragraphs (a) through (d) are identical word for word. The only edits are the dates: both the negotiation authorization and the maintenance authorization now run through 12:01 a.m. Eastern Daylight Time on October 22, 2026, in place of September 19, 2026.

That makes this a planning event rather than a compliance one. An analysis built on the previous version carries forward untouched, with one new deadline.

What OFAC GL 131J authorizes

The authorization consists of two parts. The first concerns preparation for transactions ordinarily incident and necessary to negotiating and entering into contracts with Public Joint-Stock Company Oil Company Lukoil, or any of its affiliates, for the sale, disposition, or transfer of Lukoil International GmbH (LIG) and of any entity in which LIG holds, directly or indirectly, a 50 percent or greater interest.

OFAC’s amended Frequently Asked Question (FAQ) 1224 spells out what that covers: negotiating the terms of definitive agreements, and financial, legal, and operational due diligence, including retaining outside counsel and advisers.

The condition attached to it is absolute. Performance of any resulting contract must be expressly contingent on a separate authorization from OFAC. The term “contingent contracts” is read broadly, capturing executory contracts and pro forma invoices, agreements in principle, binding memoranda of understanding, and bids or proposals submitted in response to public tenders. A signed deal is permitted. A closed deal is not.

The second part authorizes transactions that are ordinarily incident and necessary to maintain the operations of companies within the LIG perimeter or to wind down those operations. Blocked accounts of those companies may be debited and credited for these purposes. FAQ 1225 provides practical examples, including fuel and lubricants, rent and insurance, property maintenance and environmental services, salaries and severance payments, IT and legal services, payments to government authorities, and payments to suppliers, landlords, creditors, and business partners. Certain transactions under pre-existing contracts and certain intra-group transfers are also authorized, provided they are consistent with established practice and support existing projects or operations.

Where the risk actually sits

Two features of this license deserve attention from anyone with money or a contract inside the LIG perimeter.

The first is that permission to negotiate is not permission to close. Every transfer of an asset still requires a separate specific OFAC license, applied for on its own facts.

The second is revocability. OFAC states that it may withdraw the license at any time, including if Lukoil and LIG do not appear to be negotiating in good faith. Preparation costs are therefore exposed to a judgment that neither the buyer nor the seller controls.

We advise on the US sanctions questions these situations raise: whether a given transaction falls inside a current authorization, and how to build a specific license application. We do not advise on the commercial terms or the valuation of the transaction.

What the License Does Not Authorize

Three limitations that GL 131J does not lift are worth highlighting separately. They remain unchanged from the prior version.

• The license does not authorize the unblocking of property, except to the extent that blocked accounts of LIG Entities may be used for transactions expressly authorized by the license.
• Transactions involving other blocked persons under the RuHSR remain prohibited unless separately authorized.
• The transfer of funds to any person located in the Russian Federation, or to any account located in the Russian Federation, is not authorized.

The last restriction is particularly important for payment routing. It turns on the location of the recipient or the account, not merely on the recipient’s sanctions status. As a result, a transaction that is otherwise permissible in substance may still fall outside the scope of GL 131J if the funds are to be transferred to a person or an account in Russia.

What OFAC will require before approving a sale

FAQ 1224 sets out the conditions OFAC expects a proposed sale to satisfy, at a minimum:

• LIG’s ties with Lukoil must be severed completely.
• Funds owed to Lukoil must be blocked in an account subject to US jurisdiction until sanctions are lifted.
• The structure must give Lukoil no windfall, including no up-front value delivered through asset or share swaps.

OFAC adds that a future license is expected to require the purchaser to return for OFAC review before further divesting material LIG assets: the constraint outlives the closing.

Two licenses, two expiry dates

GL 128C, issued under the same RuHSR program (31 C.F.R. part 587), covers a narrower set: Lukoil retail service stations outside Russia, carved out in December 2025 so that the designation would not land on retail consumers. It runs to October 29, 2026, a week beyond OFAC GL 131J, so anyone exposed to both segments tracks two dates.

Since December 2025, OFAC has issued eleven versions of the divestment license, GL 131 and GL 131A through GL 131J, and not one authorization to complete a sale. The window keeps reopening on unchanged terms. October 22 is the next date to plan against.