On May 18, 2026, the Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) issued General License 134C (GL 134C), replacing the expired GL 134B. The new license extends the authorization for certain transactions involving Russian-origin crude oil and petroleum products already loaded on vessels. GL 134C is the latest link in a series of temporary exemptions from US sanctions on Russian oil – a series that preserves the sanctions regime intact while signaling the direction of U.S. energy sanctions policy.

Background: The US Sanctions Framework on the Russian Oil Sector

Since February 2022, the United States has steadily expanded its sanctions against the Russian energy sector. The primary regulatory authorities are the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587) and the Ukraine-/Russia-Related Sanctions Regulations (31 CFR part 589). In October 2025, OFAC added Rosneft and Lukoil, two of Russia’s largest oil companies, to the Specially Designated Nationals and Blocked Persons (SDN) List, fundamentally altering the compliance landscape for U.S. persons and other foreign counterparts dealing in Russian-origin oil.

US sanctions on Russian oil cover a broad range of transactions: imports, transportation, insurance, financing, and services related to the production and sale of Russian-origin petroleum. U.S. persons are prohibited from engaging in such transactions without specific authorization from OFAC.

The GL 134 Series: A Timeline

The series of temporary licenses governing exemptions from the sanctions regime for Russian oil cargoes began in March 2026.

On March 5, 2026, OFAC issued GL 133 – a license limited to Indian purchasers and cargo loaded before March 5, 2026, effective through April 4, 2026.

On March 12, 2026, GL 134 followed – broader in scope, with no country-of-destination restriction, covering cargo loaded before March 12, 2026, and effective through April 11, 2026. On March 19, GL 134A replaced GL 134 in its entirety, retaining the same parameters.

On April 17, 2026, OFAC issued GL 134B: the cargo cutoff moved to April 17, 2026, and the authorization extended through May 16, 2026.

On May 18, 2026, GL 134C was issued. Its parameters are addressed below.

GL 134C: What Is Authorized and Through When

GL 134C authorizes all transactions ordinarily incident and necessary to the sale, delivery, or offloading of crude oil and petroleum products of Russian Federation origin loaded on any vessel on or before 12:01 a.m. EDT on April 17, 2026. The authorization is effective through 12:01 a.m. EDT on June 17, 2026.

The following transactions and services fall within the scope of the license:

– safe docking and anchoring of vessels;

– preservation of crew health and safety;

– emergency repairs and environmental mitigation activities;

– vessel management, bunkering, piloting, registration, flagging, insurance, classification, and salvage.

The license extends to crude oil and petroleum products produced by blocked entities, including Rosneft, Lukoil, and their subsidiaries, as well as vessels blocked under applicable sanctions programs. This is what makes GL 134C practically significant for a substantial portion of the market.

The Key Distinction: The Cargo Cutoff Did Not Move

GL 134C differs from its predecessors in one critically important respect: the cargo cutoff date remains unchanged at April 17, 2026. OFAC did not advance the cutoff, as it had done at each prior step in the series. What was extended is solely the window within which transactions involving already-loaded cargo may be completed: from May 16 to June 17, 2026, an additional month.

This distinction matters. Oil loaded after April 17, 2026, is not covered by GL 134C. The license does not create new authorization for fresh Russian oil cargoes; it provides only for the orderly completion of transactions involving shipments already in transit.

What GL 134C Does Not Cover

GL 134C expressly excludes transactions involving persons located in or organized under the laws of Iran, the Democratic People’s Republic of Korea, Cuba, the covered regions of Ukraine as defined by Executive Order 14065, and the Crimea region of Ukraine as defined by Executive Order 13685, as well as entities owned or controlled by, or in a joint venture with, such persons.

The license also does not extend to transactions prohibited by other executive orders or other parts of 31 CFR chapter V not expressly referenced in its text, including transactions involving Iran or Iranian-origin goods and services prohibited by the Iranian Transactions and Sanctions Regulations (31 CFR part 560), except to the extent expressly authorized by paragraph (a) of the license.

The Logic of Temporary Exemptions

The GL 134 series reflects a consistent policy line: US sanctions on Russian oil remain fully in force, but OFAC permits narrow, time-limited exemptions for cargoes that were already physically at sea at the time each prior license was issued.

This approach serves several objectives simultaneously. First, it reduces short-term pressure on global energy markets without creating permanent carve-outs from the sanctions regime. Second, it provides market participants with a predictable window to complete transactions already underway, without immediate exposure to sanctions liability. Third, it allows the US executive branch to manage the competing policy imperatives of maintaining pressure on Russia and preserving stability in global oil trade.

It is important to understand that GL 134C does not expand or soften US sanctions on Russian oil. It is a tool for the orderly wind-down of specific transactions, not a basis for long-term planning. Companies counting on a permanent exemption or expecting the cutoff to move again may find themselves seriously exposed.

Conclusion

GL 134C is not a retreat from US sanctions on Russian oil, nor a softening of them. It is a technical instrument providing an orderly exit for a specific category of transactions already in progress. The cargo cutoff has not moved. The authorization runs through June 17, 2026. The excluded jurisdictions and counterparties remain the same.

For traders, shipowners, financial institutions, and insurers, the practical takeaway is clear: any transaction involving Russian-origin oil requires careful analysis of compliance with the terms of the applicable license. Any deviation from those terms carries the full weight of sanctions liability.

Fesenko, P.C. Law Offices advises clients on the application of OFAC general licenses and sanctions compliance under U.S. Russia-related sanctions, including in the oil sector. Contact us to learn how we can assist.