The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 128D, “Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia;” and Russia-related General License 130B, “Authorizing Transactions Involving Certain Lukoil Entities in Bulgaria.”

Additionally, OFAC is issuing Iran-related General License FF, “Authorizing the Wind Down of Transactions Involving International Development Bank for Investment and Finance.”

OFAC is also issuing one new, Cuba-related Frequently Asked Question (FAQ 1276), and one amended, Russia-related Frequently Asked Question (FAQ 1225).

Here are the FAQs – the two Russian ones:

and

and the Iran one:

and the FAQs – the Cuba one:

1276. On October 15, 2026, the Department of State designated the Banco Internacional de Comercio, S.A. (BICSA) pursuant to Executive Order (E.O.) 14404. Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with BICSA?

Answer

The U.S. government does not intend to target foreign persons, including FFIs, pursuant to E.O. 14404 for engaging in transactions ordinarily incident and necessary to the divestment from or the wind down of transactions involving BICSA, or any entity in which BICSA owns, directly or indirectly, a 50 percent or greater interest, through November 14, 2026. However, non-U.S. persons, including FFIs, should proceed with caution in any dealings with a party sanctioned under this authority. Actions to return assets to a sanctioned party or transfer them to another jurisdiction for potential use by the target could expose non-U.S. persons to significant sanctions risk.

Foreign persons unable to divest from or wind down transactions involving BICSA, or any entity in which BICSA owns, directly or indirectly, a 50 percent or greater interest, before November 14, 2026, are encouraged to contact the OFAC Compliance Hotline.

Persons subject to U.S. jurisdiction, including U.S. persons and entities owned or controlled by U.S. persons, should additionally note that this limited non-targeting posture does not authorize any transaction prohibited by the Cuban Assets Control Regulations (CACR), 31 CFR part 515, or any other OFAC sanctions authority. Persons subject to U.S. jurisdiction have long been prohibited from transacting with BICSA, a Cuban State-Owned entity, absent OFAC authorization. Accordingly, persons subject to U.S. jurisdiction continue to be prohibited from engaging in transactions involving BICSA, including in connection with a non-U.S. person’s wind down of activities with BICSA, unless separately authorized by OFAC. Relevant authorizations may include humanitarian and diplomatic-related transactions authorized under the CACR in subpart E of part 515 and under E.O. 14404 via General License (GL) 1 and GL 4A. For additional information on GL 1, see FAQ 1253.

Date Released

October 15, 2026

and the Russia one:

1225. What activities do Russia-related General License 128D and General License 131Jauthorize related to Lukoil International GmbH (LIG)?

Answer

OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”): GL 128D and GL 131J. The GLs are similar but have different expiration dates and terms as each serves a different purpose.

• To mitigate the effects of Lukoil’s OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation. OFAC subsequently issued GL 128C and GL 128D to extend the existing authorization until April 24, 2027.
• To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities. OFAC subsequently issued GLs 131B, 131C, 131D, GL 131E, GL 131F, GL 131G, GL 131H, GL 131I, and GL 131J, to extend the existing authorization until October 22, 2026. Please see Frequently Asked Question 1224for additional information on authorizations regarding negotiations for the sale of LIG Entities.

GL 128D and GL 131J expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128D and GL 131J. Transactions undertaken in the ordinary course of business may involve (but are not limited to): supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. Also, both GL 128D and GL 131J authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.

Both GL 128D and GL 131J also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.

Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128D and GL 131J. Similarly, non-U.S. persons may rely upon GL 128D and GL 131J regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128D and GL 131J, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.

Date Updated: October 15, 2026

Date Released

December 4, 2025