OFAC today issued a notice announcing the release of Russia-related General License 131A “Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities.” Here’s a simplified version:

What is this document?

This is a permission slip (General License) issued by the U.S. Treasury Department on December 10, 2025. It updates and replaces the previous “General License No. 131.”

What does it allow?

It temporarily authorizes two main types of activities related to Lukoil International GmbH (LIG), which is the international arm of the Russian oil company Lukoil:

1. Negotiating a Sale: Companies are allowed to negotiate and sign “contingent” contracts to buy LIG (or its subsidiaries) from Lukoil.
   • Note: “Contingent” means the deal cannot be finalized or executed yet. You can sign the paperwork, but the actual transfer of ownership requires separate, future approval.
2. Keeping the Lights On: It allows for the necessary transactions to keep LIG’s operations running (maintenance) or to wind them down safely. This ensures the business doesn’t collapse while potential sales are being discussed.

When does it expire?

These activities are authorized until January 17, 2026 (specifically at 12:01 a.m. EST).

What does it NOT allow?

• It does not allow the actual completion of the sale or transfer of assets (only the negotiation and signing of the initial agreement).
• It does not unblock frozen funds or property, except for the specific maintenance tasks allowed.
• It does not allow payments to other sanctioned (blocked) persons unless specifically authorized.

Why was this issued?

This license essentially creates a window of time for Lukoil to potentially divest (sell off) its international business to non-sanctioned parties, while preventing the international branch from failing in the meantime.