OFAC GL 131J: Extended to October 22, With a Warning That It Can Be Revoked
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...
OFAC GL 131I: Nine Licenses, a Signed Carlyle Deal, and Still No Approval for Lukoil
What changed in OFAC GL 131I
On August 20, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 131I under the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR), 31 C.F.R. part 587.
We compared the texts line by line. Exactly one thing moved: the date. The authorization now runs through 12:01 a.m. Eastern Daylight...
OFAC GL 131H: Eighth Extension in a Row Gives Lukoil International GmbH Deal Until August 22
On July 24, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued General License No. 131H (OFAC GL 131H), replacing General License No. 131G and extending the authorization for negotiations and contingent contracts for the sale of Lukoil International GmbH (LIG) until August 22, 2026. LIG is the Austrian holding company through which PJSC Lukoil manages...
New OFAC Reconsideration Portal: What Has Actually Changed
What OFAC Launched on June 29, 2026
On June 29, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) launched a new online tool for submitting requests to be removed from its sanctions lists: the OFAC Reconsideration Portal. The portal replaces the previous practice under which petitioners submitted delisting petitions by email and then went through repeated...
OFAC GL 131G: New General License for Transactions Involving Lukoil International GmbH
Why OFAC Issued GL 131G
On October 22, 2025, OFAC designated Public Joint-Stock Company Oil Company Lukoil as part of a broader campaign to degrade Russia’s energy revenues and its capacity to finance the war. At the same time, OFAC recognized the practical reality: Lukoil holds substantial assets outside of Russia, and an orderly divestiture of those assets to non-blocked buyers serves U.S....
Civil Nuclear Energy Sanctions: OFAC General License 115D Explained
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. 115D, “Authorizing Certain Transactions Related to Civil Nuclear Energy.” It replaced and superseded General License 115C, which had been in force since December 2025. The substance is unchanged, but the authorization now runs six months...
Lukoil GL 131F: OFAC Extends Authorization for LIG Sale Negotiations
On May 28, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 131F (Lukoil GL 131F), replacing General License No. 131E and extending the authorization through 12:01 a.m. EDT on June 27, 2026. The license continues to authorize negotiations and the entry into contingent contracts for the sale of Lukoil International GmbH (LIG), the...
OFAC general license for Russian oil: GL 134B replaces GL 134A
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...
Lukoil Sanctions: OFAC Issues GL 131D, Extending the Sale Window for Lukoil International GmbH Through May 1, 2026
On March 30, 2026, the Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) issued General License No. 131D (GL 131D), replacing GL 131C, which was set to expire on April 1, 2026. The new license extends through May 1, 2026, the authorization to negotiate and enter into contingent contracts for the sale of Lukoil International GmbH (“LIG”), the Austrian holding...
Belarus Sanctions: OFAC Lifts Restrictions on Banks and Potash Producers
On March 26, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) moved on three fronts at once. It issued General License No. 14 (GL 14), authorizing transactions with the Belarusian Bank for Reconstruction and Development, “Belinvestbank,” and its affiliates. It revoked Directive 1 under Executive Order 14038, lifting the longstanding prohibitions on dealings...