What Changed on June 11, 2026

On June 11, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 55F, “Authorizing Certain Services Related to Sakhalin-2”. It replaced and superseded General License 55E, in force since December 2025. The authorization is unchanged in substance, but its term has been extended: transactions related to the Sakhalin-2 project are now permitted through December 18, 2026.

Sakhalin-2 sanctions are built not as a blanket ban but as a narrow exception that OFAC renews roughly every six months. For those involved in the project, the extension removes uncertainty through year-end: shipments and payments can be planned without fear that the authorization will lapse over the summer.

What the Sakhalin-2 Project Is, and Why It Has an Exception

Sakhalin-2 is a large oil-and-gas project on Sakhalin Island, geared chiefly toward producing liquefied natural gas (LNG) but also yielding crude oil. Much of its output has historically gone to Japan, for which it is an important energy source. That is why the project sits in a special position: a full ban on services tied to its oil would hit the energy supply of a U.S. ally more than it would hit Russia.

To avoid disrupting Japan’s energy balance, OFAC carved out a separate exception for Sakhalin-2 from the outset and has renewed it regularly ever since. GL 55F is the latest version of that mechanism.

What OFAC General License 55F Authorizes

Sakhalin-2 sanctions do not amount to a complete prohibition: OFAC General License 55F authorizes three groups of project-related transactions that would otherwise be barred.

• maritime transport of crude oil produced by the project (the license calls it the Sakhalin-2 “byproduct”), but only where that oil is solely for importation into Japan (the ban on such services stems from a determination of November 21, 2022, under Executive Order (E.O.) 14071);
• transactions involving Gazprombank Joint Stock Company, or entities it owns 50 percent or more, that relate to the Sakhalin-2 project, including transactions involving the project operator, Sakhalin Energy LLC;
• petroleum services related to the project that would otherwise fall under the petroleum-services ban introduced by a determination of January 10, 2025 (also under E.O. 14071).

All three authorizations run through December 18, 2026. Beyond their edges the risk zone begins: the license covers the Sakhalin-2 project specifically and does not extend to other dealings.

The Japan Carve-Out for Oil

The first and most distinctive limb of the license is the authorization for services related to the maritime transport of Sakhalin crude. It is not unconditional: it applies only where the oil is solely for importation into Japan. This follows directly from the underlying policy logic: the United States does not want to collapse Japan’s energy supply, so it keeps a channel open for Japan while closing it for every other destination.

The practical upshot is that the cargo’s destination is decisive. The same shipment of the same oil, bound elsewhere, no longer falls under the license. Documentary proof of the final destination is therefore not a formality but a condition of the transaction’s lawfulness.

Where Gazprombank Comes In

The second limb concerns Gazprombank. Until November 21, 2024, it was not under blocking sanctions, and Sakhalin-2 settlements flowed through it freely. On that day, OFAC added Gazprombank to the Specially Designated Nationals (SDN) List, and any dealings with it became prohibited for U.S. persons under Executive Order 14024.

Without this exception, blocking Gazprombank would have paralyzed project settlements, including those of its operator, Sakhalin Energy LLC. The license, therefore, authorizes project-related transactions involving Gazprombank and entities it controls at 50 percent or more. That is why Sakhalin-2 sanctions are inseparable from the Gazprombank question: without this authorization, the project would lose its legitimate economic meaning for Western counterparties.

What the License Does Not Authorize

The license opens a narrow corridor but leaves the adjacent prohibitions intact. OFAC General License 55F expressly does not authorize:

• transactions prohibited by Directive 2 (the ban on correspondent and payable-through accounts and on processing transactions for certain foreign financial institutions);
• transactions prohibited by Directive 4 (the ban on dealings with the Central Bank of Russia, the National Wealth Fund, and the Ministry of Finance);
• any other transaction prohibited by 31 CFR Part 587, including dealings with blocked persons other than those named in the license.

Breach any of these limits, and a nominally permitted “Sakhalin” transaction becomes a sanctions violation.

How to Structure the Payment Correctly

Gazprombank has been on the SDN List since November 21, 2024, meaning it is blocked, and project transactions involving it are by default prohibited under Executive Order 14024. OFAC General License 55F (paragraph (b)) expressly authorizes Sakhalin-2 transactions involving Gazprombank and entities it controls at 50 percent or more, including Sakhalin Energy LLC, within the license’s term.

Such payments may therefore be processed under the license, including with the participation of U.S. banks, provided that the transaction: (i) is genuinely project-related and falls within the categories the license authorizes, and the oil to be transported is intended solely for importation into Japan; (ii) does not involve other blocked persons or banks not covered by the license, in particular those subject to Directive 2 (CAPTA), such as Sberbank, or to Directive 4; and (iii) does not breach any other prohibition of the 31 CFR Part 587 regime. In practice, correspondent banks often require additional payment structuring out of caution, but that is a matter of the bank’s risk compliance, not a direct requirement of Directive 2.

In practice, the Sakhalin-2 sanctions exception is narrowly drawn: the authorization exists, but an error in the payment structure, stepping outside the project, or the absence of confirmation of the cargo’s Japanese destination turns a lawful transaction into a violation.

How a Sanctions Lawyer Can Help

Sakhalin-2 sanctions are an area where authorization and prohibition are separated by a thin line: a substantively correct transaction can become a violation through the wrong payment route, an unconfirmed cargo destination, or stepping outside the project. Our practice focuses on U.S. sanctions law: we assess whether a given transaction falls under an OFAC general license, build a compliant payment structure, and prepare the supporting rationale for the bank. That lets clients use the authorization as intended and reduces the risk of a refusal.