On March 12, 2026, exactly one week after issuing General License No. 133 (“GL 133”), the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published General License No. 134 (“GL 134”). The new license authorizes all transactions necessary for the sale, delivery, and offloading of Russian-origin crude oil and petroleum products loaded onto vessels on or before March 12, 2026, with a wind-down deadline of April 11, 2026. Unlike GL 133, which targeted Indian buyers exclusively, GL 134 is universal: it imposes no requirements as to the buyer’s nationality or the port of destination.

GL 133 and GL 134 complement each other: the first addressed oil and petroleum products that had accumulated by March 5; the second covers cargo loaded during the following week. To understand why OFAC needed a second license so quickly and what this may signal for the future of Russian oil sanctions, one must examine the circumstances that led to both.

How GL 134 Relates to GL 133: Two Licenses, One Logic

OFAC issued GL 133 on March 5, 2026, against the backdrop of an unmistakably exceptional moment. Treasury Secretary Scott Bessent publicly described it as “an intentionally short-term measure” limited to oil “already at sea”. That framing clearly implied a one-off: GL 133 would do its job quickly, and Russian oil sanctions would resume their normal course.

The Trump administration, however, appears to have underestimated the duration and scale of the Iran war’s impact on global oil prices. Stabilization did not materialize. Prices again broke the one-hundred-dollar-per-barrel threshold, and the Trump team is once again searching for solutions that might at least contain the rally in the short term.

One such solution is to relax Russian oil sanctions. According to analysts, approximately 121 million barrels of Russian oil sat aboard tankers at sea as of Friday, March 13. GL 134 is OFAC’s answer to that reality.

What GL 134 Authorizes — and What Remains Prohibited

Like its predecessor, GL 134 covers the full range of operations typically associated with the sale, delivery, and offloading of Russian oil: safe mooring and anchorage, crew medical services, emergency repairs, environmental response, vessel management, bunkering, pilotage, registration, insurance, classification, and salvage operations. Notably, the license extends even to blocked vessels appearing on the SDN List.

Unlike GL 133, however, GL 134 contains no geographic restriction. The absence of any buyer-country or destination-port requirement is not a technical detail; it signals that the geopolitical calculus shifted within a single week.

That said, several restrictions remain intact. Neither license authorizes any transaction prohibited under Iran sanctions. The risk of secondary sanctions for third countries remains in force. And oil or petroleum products loaded after March 12 fall entirely outside the license.

The Geopolitical Dimension: Why the India Restriction Disappeared

In our analysis of GL 133, we identified three objectives: stabilizing the oil market, drawing India closer to the American orbit through the Quad framework, and incentivizing Russian neutrality in the Iran conflict. GL 134 revises that picture in one material respect: by dropping the India restriction, it expands the pool of beneficiaries.

The exclusively Indian focus of GL 133 likely generated diplomatic friction with other U.S. partners, particularly in Southeast Asia and Europe, that also import Russian oil but cannot rely on GL 133. By removing the geographic restriction in GL 134, OFAC quietly extended its reach to a broader set of trading partners.

There is also a straightforward commercial explanation. The tanker market does not respect national boundaries, as a geographically targeted license assumes. A cargo designated for India at the time of departure may be redirected to a different jurisdiction mid-voyage. GL 134 thus eliminates a compliance trap that GL 133 inadvertently created for market participants operating in this highly dynamic commercial space.

What These Two Licenses Mean for Russian Oil Sanctions

In our GL 133 analysis, we outlined three scenarios: limited precedent, instrumentalization of Russian oil sanctions, and regime erosion. GL 134 provides new material for that assessment.

The limited-precedent scenario, in which GL 133 would remain a force-majeure exception, has already been undermined. OFAC issued two consecutive licenses within one week, and the second does not merely extend the first: it broadens its scope. If the Iran crisis persists, pressure on the Trump administration to expand carve-outs will only intensify.

The instrumentalization scenario remains the most compelling analytically. GL 134 confirms that the Treasury has a refined toolkit for targeted, time-limited exemptions that leave the broader sanctions architecture intact. That same toolkit may come into play in the context of a Ukraine settlement, should negotiations reach their final stage: limited sanctions relief could become a component of a broader “package” deal.

The regime-erosion scenario remains on the table, though its trajectory is not yet clear. What is clear is that each successive license, especially one that expands rather than merely extends its predecessor, lowers the political threshold for further carve-outs.

Practical Takeaways for Business

For companies operating in international trade, shipping, vessel finance, and related services, GL 134 raises several concrete compliance questions.

First, the loading date is the critical parameter. GL 134 covers cargo loaded onto a vessel before 12:01 a.m. EDT on March 12, 2026. Any cargo loaded after that moment receives no protection. Companies must ensure they hold clear documentation establishing the loading date: bills of lading, port clearances, and vessel logs.

Second, the Iran factor demands separate attention. A vessel that called at an Iranian port, carried Iranian cargo, or maintains other Iran-related connections may fall outside the license’s authorization, even if the Russian cargo was loaded before March 12.

Third, counterparty screening must extend beyond GL 134’s explicit scope. Restrictions imposed under sanctions authorities not expressly referenced in GL 134 remain in force, and the license does not lift them.

Fourth, and perhaps most importantly, the one-week interval between GL 133 and GL 134 makes the point unmistakable: the regulatory landscape can shift very fast. Compliance programs operating on a quarterly update cycle are structurally inadequate for this environment. Real-time monitoring of OFAC regulatory developments is an operational necessity for any company with exposure to Russian oil. If managing that in-house is not feasible, contact us for a consultation.

Conclusion

One can characterize GL 134 as a technical instrument addressing a narrow compliance problem related to a specific category of stranded cargo. In tandem with GL 133, however, it reveals something larger: OFAC actively manages Russian oil sanctions in real time and can expand the scope of relief very quickly when geopolitical or commercial logic demands it, without offering any public explanation. For market participants, that is both a risk and an opportunity worth understanding.