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...
Sakhalin-2 Sanctions: OFAC General License 55F 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. 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 It replaced and superseded General License 55E, in force since December 2025.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...
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 It replaced and superseded General License 115C, which had been in force since December 2025.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...
OFAC Blocked Wire Transfer: How to Recover Your Funds Through a Specific License
An OFAC blocked wire transfer puts both the sender and the recipient in a difficult legal position. The block itself is not final, U.S. sanctions law provides a mechanism for releasing funds: the OFAC specific license. Obtaining one, however, requires a carefully constructed legal position, and the quality of that position often determines the outcome.
This article walks through the process...
US Sanctions on Russian Oil: GL 134C and the Logic of Temporary OFAC Licenses
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...
Lukoil Foreign Assets Sale: GL 131E Extends the Negotiation Window to May 30, 2026
What Happened on April 29, 2026
On April 29, 2026, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) issued General License No. 131E (GL 131E), extending the authorization for negotiations and the execution of conditional contracts for the sale of Lukoil International GmbH (LIG), the Austrian holding company through which Lukoil manages its foreign operations. The new...
Sanctions on Russian Oil: OFAC Amends GL 134
On March 19, 2026, exactly one week after issuing GL 134, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published General License GL 134A, which superseded GL 134 on the same date. The core authorization covering sanctions on Russian oil remains intact: GL 134A still permits the sale, transport, and offloading of Russian petroleum and petroleum products loaded...
Russian Oil Sanctions: GL 134 Follows GL 133
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,...
U.S. Oil Sanctions: The Russia Card
On March 5, 2026, the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury published a document introducing significant adjustments to U.S. oil sanctions against Russia. General License No. 133 ("GL 133") authorizes, through April 4, 2026, all transactions necessary for the sale, delivery, and offloading of Russian crude oil and petroleum products that were loaded...
Asset Freeze and How It Works
Asset freezes under U.S. sanctions have affected numerous Russian companies, their owners, and a number of foreign partners. Despite the similarity of their current legal status, the mechanisms of asset freeze can vary significantly. These differences largely determine how favorably the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) will respond to your application...