April 17, 2026 After Hours: New version of Russia-related General License 134


About 8:30 last night, I got OFAC’s notice of issuing General License 134B (Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of April 17, 2026):

Of course, this seems different from what OFAC usually does when they change versions, as opposed to issuing a new GL. Let’s let Claude explain the history of this GL:

Good question — your instinct is right that 134B is structurally unusual compared to a typical amended GL. Here’s a breakdown:

The GL 134 lineage in brief:

  • GL 134 (March 12, 2026) authorized transactions for Russian-origin oil loaded on vessels before 12:01 a.m. EDT on March 12, 2026, through April 11, 2026.
  • GL 134A (March 19, 2026) amended GL 134, keeping the same March 12 loading cutoff and April 11 expiration, but added a new prohibition in paragraph (b)(1) barring transactions involving persons in or organized under the laws of North Korea, Cuba, Iran, the Crimea, and Covered Regions of Ukraine. That Cuba exclusion was notably the key change — GL 134 had apparently left open a question about whether Cuban transactions were covered, prompting OFAC to quickly amend it.

134A → 134B: The key differences

Comparing 134A to the 134B you’ve uploaded, there are two substantive changes:

  1. Loading cutoff date extended by ~36 days — from March 12 to April 17, 2026. This is the big one.
  2. Authorization window extended — from April 11 to May 16, 2026.

The paragraph (b)(1) exclusion list (Iran, North Korea, Cuba, Covered Regions/Crimea) appears to be carried over from 134A unchanged.


Why your observation is correct

Normally when OFAC issues an amended GL (the A, B, C progression), the change is clarificatory or administrative — same underlying authorization, tweaked language. What makes 134B unusual is that extending the loading cutoff date by over a month is not a clarification — it’s a new substantive authorization covering an entirely different universe of cargo (everything loaded between March 12 and April 17 that 134A never covered at all). In effect, OFAC has used the amendment format to issue what is functionally a fresh, broader wind-down license, rather than simply extending or clarifying the original. This mirrors what OFAC did with the parallel Iran GL U series and likely reflects a deliberate policy choice to keep rolling authorizations flowing as market conditions evolve, without the optics of issuing a wholly new GL from scratch.


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