Mr. Sanctions

Category: General Licenses

  • May 26, 2026: OFSI amends Russia sanctions Personal Remittances General Licence

    Office of Financial Sanctions Implementation HM Treasury

    OFSI General Licence INT/2024/4761108 amended

    On 16 April 2026, the Personal Remittances General Licence (INT/2024/4761108), which allows non-designated persons to make or receive permitted payments via a designated credit or financial institution up to a certain limit, was amended to: 

    • include a new definition of “cryptoasset” –  a cryptographically secured digital representation of value or contractual rights that uses a form of distributed ledger technology and can be transferred, stored or traded electronically.
    • include a new reporting requirement for any person using cryptoassets to make or receive payments under the licence.

    The licence now expires on 23 February 2028.

    Any persons intending to use General Licence INT/2024/4761108 should consult the copy of the Licence for full details of the permissions and usage requirements.

    Here’s the General Licence:

    INT.2024.4761108_GL_2026.05.26_amendmentDownload

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  • May 19, 2026: OTSI (not OFSI) issues two Russia-related General Trade Licences

    The first one is related to sanctioned processed oil products (only in HTML for some reason):

    Notice

    General Trade Licence for sanctioned processed oil products

    Published 19 May 2026

    Licence number: GBSAN0004

    1․ The Secretary of State grants this General Trade Licence under regulation 65 of the Russia (Sanctions) (EU Exit) Regulations 2019 (the ‘Russia Regulations’).

    2․ The prohibitions in regulations 46Z9F, 46Z9G, 46Z9H, and 46Z9I of Chapter 4IB (relevant processed oil products) of the Russia Regulations do not apply to anything done that is authorised under this licence.

    Interpretation

    3․ For the purposes of this licence:

    a) “2709 oil and oil products” means those oil and oil products which–

    i) fall within commodity code 2709, and

    ii) originate in Russia;

    b) “oil and oil products” means anything specified in Schedule 3F to the Russia Regulations;

    c) “person” means an individual, a body of persons corporate or unincorporate, any organisation or any association or combination of persons;

    d) “relevant processed oil products” means oil and oil products which–

    i) fall within commodity code 2710, and

    ii) have been processed in a third country from 2709 oil and oil products;

    e) “third country” means any country other than the United Kingdom, the Isle of Man or Russia;

    f) paragraph 1 of Schedule 3 to the Russia Regulations applies for the purposes of—

    i) interpreting the definitions of “2709 oil and oil products” and “relevant processed oil products”, and

    ii) determining whether products fall within the commodity codes in paragraph 5 of this licence.

    Authorisations

    4․ The prohibitions specified at regulations 46Z9F, 46Z9G, 46Z9H, and 46Z9I of the Russia Regulations do not apply to relevant processed oil products, or in relation to those products, provided that the condition set out in paragraph 5 of this licence is met.

    5․ The condition is that the products fall within any of the following commodity codes:

    a) 2710 19 42 or 2710 19 44 (diesel);

    b) 2710 19 21 (jet fuel).

    General

    6․ This licence does not authorise any act which the person carrying out the act knows, or has reasonable grounds for suspecting, will result in a breach of any part of the Russia Regulations, save as authorised under this licence or any other licence granted under the Russia Regulations.

    7․ Information provided to the Secretary of State in connection with this licence shall be processed in accordance with the UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018. This information may be disclosed to third parties as permitted or required by law, including as required under the Freedom of Information Act 2000 or the Environmental Information Regulations 2004 or permitted under regulation 78 of the Russia Regulations.

    8․ This licence is subject to any obligation arising in respect of the Windsor Framework as it may apply through section 7A of the European Union (Withdrawal) Act 2018 in respect of Northern Ireland.

    9․ The provisions of regulation 76 (general trade licences: records) of the Russia Regulations apply to any act under the authority of this Licence.

    10․ This licence comes into force on 20 May 2026. It is of indefinite duration and shall be periodically reviewed by the Secretary of State.

    11․ The Secretary of State has the power to vary, revoke or suspend this licence at any time. The Secretary of State will endeavour to provide 4 months’ notice of any decision to revoke this licence.

    An Official of the Department for Business and Trade (DBT), authorised to act on behalf of the Secretary of State.

    Issued on 19 May 2026.

    Contact DBT

    Any enquiries regarding this publication should be sent to:

    Import controls and trade sanctions

    Department for Business and Trade
    Old Admiralty Building
    Admiralty Place
    London
    SW1A 2DY

    Email importsanctions@businessandtrade.gov.uk

    If you require this publication in an alternative format, email importsanctions@businessandtrade.gov.uk.

    and the second one is related to liquefied natural gas (in HTML and PDF):

    general_trade_licence_maritime_transportation_of_LNG_Download

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  • May 18, 2026: OFAC Updates, Part 1: New version of that Russian Oil GL

    Yes, I am doing my “updates” in reverse order… that way I can post this while Claude chugs along on the designations…

    It’s Russia-related General License 134C (Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of April 17, 2026):

    russia_gl134cDownload

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  • Notice to Exporters 2026/13: I do declare (on the UK’s customs declaration system)

    Export Control & Sanctions

    NTE 2026/13: declaring exports under OGELs and GEAs on the UK’s customs declarations system

    Published 13 May 2026

    Introduction

    When exporters register to use Open General Export Licences (OGELs) or General Export Authorisations (GEAs), they are given a unique licence reference in the form ‘GBOGE20XX/XXXXX’.

    The UK’s Customs Declarations System (CDS) includes a field, currently box 44, where this licence reference can be entered. Presently only a small number of OGELs have a condition that requires exporters to enter this field on CDS.

    We will be updating all relevant OGELs in the coming months to add a condition requiring the licence reference to be entered on CDS for all tangible exports. Including the licence reference on CDS will bring tangible exports made under OGELs and GEAsinto line with Standard Individual Export License (SIELs) and Open individual export licence (OIEL). The roll-out of this requirement across all relevant OGELs aims to deliver data that will help us to maintain the appropriate balance between transparency and administrative burden whilst providing insight into OGEL usage and trends.

    When this becomes a condition on relevant licences, the inclusion of the licences reference on CDS will be an enforcement matter for HM Revenue and Customs (HMRC). To ensure a smooth transition for OGEL users, export control joint unit (ECJU) are encouraging exporters to employ good practice by including their OGEL or GEA licence reference on CDS now.

    Using Freight Forwarders

    When using freight forwarders, exporters must provide the correct licence reference and an instruction to ensure the licence is correctly referenced in the Customs Declaration Service.  An incorrect declaration could constitute a criminal offence under Customs and Excise Management Act (CEMA) Article 167. The exporter of the goods and any agent concerned in the exportation or shipment may be considered responsible for the accuracy of a declaration.

    More information on using freight forwarders and customs agents can be found here.

    Updating information on CDS

    If the licence reference is missed or incorrectly added, a CDS entry can be amended at any time until cleared. If already cleared, exporters can complete a C1700 form and advise that a licence was omitted from the declaration, HMRC will then be able to amend the record to show licence usage.

    Record Keeping

    Each declaration on CDS generates an Export Entry Reference. Exporters must keep a record of this reference, or a copy of the entry with the other records they are required to keep for that export. Where exporters use freight forwarders to make a declaration on their behalf, they should request that the freight forwarder provide them with this refence number or a copy of the entry.

    Get customs data for import and export declarations – GOV.UK

    Where can you find the Licence Reference

    You can find the unique licence reference number by logging into your SPIRE account and checking the SPIRE letter that confirmed your registration. If you registered for multiple OGELs or GEAs at the same time the letter will contain a unique licence reference for each OGEL or GEA you registered for.

    OGELS with no registration requirements

    For certain OGELs, there is no requirement to register to use it meaning there will be no associated unique licence reference for exporters to enter into CDS. For these OGELs, a condition will be added requiring a reference relating to the OGEL name to be entered onto CDS. The required text will be set out in each OGEL. The OGELs with no registration requirements are:

    Contact ECJU

    General queries about strategic export licensing

    Export Control Joint Unit
    Department for Business and Trade
    Old Admiralty Building
    Admiralty Place
    London
    SW1A 2DY

    Email exportcontrol.help@businessandtrade.gov.uk

    Telephone 020 7215 4594

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  • May 7, 2026: OFAC Update, Part 2: The first Cuba GL I can remember, and 6 new FAQs

    Here it is: Cuba General License 1 (Transactions Authorized Pursuant to the Cuban Assets Control Regulations):

    cuba_gl1Download

    and Frequently Asked Questions 1251-1256:

    1256. Are all persons that operate or have operated in the five sectors of the Cuban economy identified in E.O. 14404 sanctioned by OFAC under E.O. 14404?  

    No. E.O. 14404 authorizes the Secretary of the Treasury, in consultation with the Secretary of State, or the Secretary of State, in consultation with the Secretary of the Treasury, to impose blocking sanctions on any foreign person determined to operate or have operated in the following sectors of the Cuban economy: (1) energy; (2) defense and related materiel; (3) metals and mining; (4) financial services; and (5) security. E.O. 14404 also authorizes the Secretary of the Treasury, in consultation with the Secretary of State, to determine that the prohibitions in section 2(a)(i)(A) of E.O. 14404 apply to additional sectors of the Cuban economy.

    The identification of these sectors exposes foreign persons that operate or have operated in such sectors to sanctions risk; however, it does not automatically impose sanctions on all persons who operate or have operated in those sectors. Only foreign persons determined pursuant to E.O. 14404 to operate or have operated in an identified sector are subject to sanctions under this criterion.

    Persons should also note that E.O. 14404 is separate from the Cuban Assets Control Regulations (CACR), 31 CFR part 515. A person that is not sanctioned pursuant to E.O. 14404 may still be subject to CACR prohibitions or restrictions. For further information regarding the CACR prohibitions, please see FAQs 1252, 1254, and 1255.

    Released on May 07, 2026

    Cuba Sanctions

    1255. Are persons blocked pursuant to the Cuban Assets Control Regulations (CACR), 31 CFR part 515, automatically blocked pursuant to the E.O. 14404?  

    No. Persons blocked or otherwise identified pursuant to the CACR are not automatically blocked pursuant to the E.O. 14404. The CACR and E.O. 14404 are separate sanctions authorities. E.O. 14404 separately authorizes the imposition of blocking sanctions and certain less-than-blocking sanctions against foreign persons determined to meet one or more of the criteria in E.O. 14404. Persons sanctioned under the CACR are only subject to sanctions under E.O. 14404 if such persons are separately determined by the Secretary of the Treasury or the Secretary of State to meet the criteria under E.O. 14404.

    Persons listed on OFAC’s Specially Designated Nationals and Blocked Persons List may be identified under one or more sanctions authorities.

    Released on May 07, 2026

    Cuba Sanctions

    1254. On May 7, 2026, the Department of State designated the Cuban entity Grupo de Administración Empresarial S.A. (GAESA) pursuant to E.O. 14404. Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with GAESA? 

    Generally, yes, but 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 wind down of transactions involving GAESA, or any entity in which GAESA owns, directly or indirectly, a 50 percent or greater interest, through June 5, 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 wind down transactions involving GAESA, or any entity in which GAESA owns, directly or indirectly, a 50 percent or greater interest, before June 5, 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 GAESA, a Cuban military-controlled entity, absent OFAC authorization. GAESA has been identified on the List of Specially Designated Nationals and Blocked Persons (SDN List) and the State Department-administered Cuba Restricted List since December 21, 2020. Accordingly, persons subject to U.S. jurisdiction continue to be prohibited from engaging in transactions involving GAESA, including in connection with a foreign person’s wind down of activities with GAESA, unless separately authorized by OFAC.

    Released on May 07, 2026

    Cuba Sanctions

    1253. What does Cuba-related General License (GL) 1, “Transactions Authorized Pursuant to the Cuban Assets Control Regulations,” authorize?  

    On May 7, 2026, OFAC issued Cuba-related GL 1, authorizing all transactions prohibited by E.O. 14404 where such transactions are authorized or exempt under the Cuban Assets Control Regulations, 31 CFR part 515 (CACR).

    GL 1 includes transactions authorized by either general or specific license issued pursuant to the CACR. GL 1 is intended to ensure activity authorized or exempt under the CACR is not interrupted if a foreign person already blocked or otherwise identified under the CACR is also blocked pursuant to E.O. 14404, such as Grupo de Administración Empresarial S.A. (GAESA). In such cases, no additional OFAC authorization beyond GL 1 would be required to engage in CACR-authorized activities.

    GL 1 does not expand the scope of any authorization or exemption under the CACR. Any transaction must continue to comply with all relevant conditions and limitations as provided in the CACR to be authorized under GL 1. As with all OFAC GLs, GL 1 is “self-executing,” meaning that persons who assess that their transactions fall within the scope of the authorization may proceed without further assurance from OFAC. Transactions prohibited by E.O. 14404 require additional OFAC authorization if not authorized or exempt under the CACR.

    Released on May 07, 2026

    Cuba Sanctions

    1252. Does E.O. 14404 alter U.S. sanctions on Cuba pursuant to the Cuban Assets Control Regulations (CACR)?  

    No. All existing prohibitions and authorizations pursuant to the CACRremain in effect.

    E.O. 14404 was issued pursuant to the International Emergency Economic Powers Act (IEEPA), and is distinct from the CACR, which is issued pursuant to the Trading with the Enemy Act (TWEA), among other statutes. These authorities function in parallel. E.O. 14404 establishes the authority for a new Cuba-related sanctions program that includes blocking sanctions and certain less-than-blocking sanctions against foreign persons determined to meet one or more of the criteria in E.O. 14404.

    Simultaneously, OFAC continues to administer the CACR, including its prohibitions, authorizations, and exemptions. OFAC maintains the authority to identify certain persons on the List of Specially Designated Nationals and Blocked Persons (SDN List) under the CACR, including persons acting for or on behalf of the Government of Cuba. However, the CACR continues to operate as a jurisdictional sanctions program focused specifically on Cuba and Cuban nationals.

    Furthermore, Sections 2(b) and 4(c) of E.O. 14404 state that the relevant prohibitions found in E.O. 14404 do not affect the validity of licenses issued pursuant to the CACR.

    Released on May 07, 2026

    Cuba Sanctions

    1251. What does Executive Order (E.O.) 14404 of May 1, 2026, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to U.S. National Security and Foreign Policy,” do? 

    E.O. 14404 takes additional steps with respect to the national emergency declared in E.O. 14380 of January 29, 2026, “Addressing Threats to the United States by the Government of Cuba.” E.O. 14404authorizes the imposition of sanctions by the Secretary of the Treasury and the Secretary of State on foreign persons determined to be involved in specified harmful activities related to Cuba, including:

    • operating, or having operated in identified sectors of the Cuban economy (e.g., Cuba’s energy, defense and related materiel, metals and mining, financial services, and security sectors);
    • acting for or on behalf of, or providing support to, the Government of Cuba or persons blocked pursuant to E.O 14404; and 
    • being responsible for or complicit in serious human rights abuse or corruption related to Cuba.

    E.O. 14404 establishes a new Cuba-related sanctions program under the International Emergency Economic Powers Act (IEEPA) that is separate from, and in addition to, the Cuban Assets Control Regulations (CACR), 31 CFR part 515. All existing CACR prohibitions and authorizations remain in effect. E.O. 14404 also expressly states that prohibitions within and actions taken pursuant to E.O. 14404 do not affect the validity of licenses issued pursuant to the CACR. Additionally, on May 7, 2026, OFAC issued Cuba-related General License 1, “Transactions Authorized Pursuant to the Cuban Assets Control Regulations,” authorizing all transactions prohibited by E.O. 14404 where transactions are authorized or exempt under the CACR. See FAQ 1253 for additional information.

    While the United States has long maintained sanctions on Cuba and Cuban nationals pursuant to the CACR, E.O. 14404 broadens U.S. sanctions on Cuba to include authorizing sanctions on non-Cuban foreign persons for providing support to Cuba and on foreign financial institutions for conducting or facilitating significant transactions involving persons blocked pursuant to E.O. 14404. Foreign persons, including foreign financial institutions, should be aware of the new sanctions risk for engaging in certain conduct with Cuba as outlined in E.O. 14404.

    Released on May 07, 2026

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  • Burning Question: So how different is OFAC Venezuela-related General License 58?

    Claude compares and contrasts GL58 with other Venezuela GLs and, to be honest, comes up with a really interesting detailed analysis that, to be fair, I’m not sure I could reproduce:

    This is a genuinely distinctive license. Let me walk through what makes it unusual compared to the rest of the Venezuela GL landscape.

    What GL 58 does: It authorizes U.S. persons to provide legal, financial advisory, and consulting services to the Government of Venezuela and PdVSA in connection with potential restructuring of GoV/PdVSA debt. It was signed by OFAC Director Bradley T. Smith and dated today, May 5, 2026.

    What makes it different from the other Venezuela GLs:

    1. It’s debtor-side, not creditor-side or commerce-side. This is perhaps the most striking feature. The entire wave of 2026 Venezuela GLs — GL 46B through GL 57 — has been about enabling U.S. commercial actors to engage in trade, investment, and financial services with Venezuela. These GLs provide opportunities for U.S. persons to engage in business related to the oil and gas, petrochemical and metals and mining industries in Venezuela, albeit under certain conditions. GL 58 flips the perspective: it authorizes U.S. professionals to advise the Venezuelan government itself on how to restructure its debt obligations. That’s a fundamentally different posture — it’s enabling the debtor to get professional help, not enabling creditors or commercial parties to do business.

    2. It authorizes preparation but explicitly prohibits execution. Paragraph (b)(1) creates a sharp firewall: the actual restructuring, transfer, or settlement of debt is not authorized, nor are direct negotiations between GoV/PdVSA and creditors. The license only covers assessment, development, and preparation of restructuring options and proposals (Note 2 to paragraph (a)). This “preparation only” structure is unusual. Compare this to GL 49A and GL 56, which authorize negotiating and entering into contingent contracts — those GLs let parties reach binding agreements (contingent on further OFAC authorization). GL 56 permits transactions necessary to negotiate contingent commercial contracts with the Government of Venezuela across all sectors, provided contracts expressly condition performance on separate OFAC authorization. GL 58 doesn’t even go that far; it stops at the advisory stage before any negotiating table is set.

    3. It sits in tension with the GL 5 series. The GL 5 line (now at 5W, issued just yesterday) has spent years blocking the enforcement of bondholder rights to CITGO shares. OFAC issued GL 5W on May 4, 2026, which further delays the effectiveness of the authorization — pushing the CITGO bondholder enforcement window out to June 19, 2026. So OFAC is simultaneously preventing creditors from seizing collateral while now enabling the debtor to get professional advice on restructuring. Read together, GL 5W and GL 58 suggest OFAC is trying to steer the situation toward a negotiated resolution rather than a disorderly collateral seizure.

    4. The dual-agency reporting requirement is unusual. Paragraph (c) requires that signed service contracts be furnished to both the State Department (Sanctions_inbox@state.gov) and the Department of Energy (VZReporting@doe.gov) within 10 business days. Most other Venezuela GLs don’t impose this kind of contract-reporting obligation. The DOE involvement underscores the energy-sector dimension of PdVSA’s debt, while State Department involvement signals foreign policy coordination.

    5. The payment-method prohibitions are notably specific. Paragraph (b)(2) bars payment terms involving debt swaps, gold, or Venezuelan government-issued digital currency including the petro. No other GL I’ve reviewed spells out payment-method restrictions with this level of specificity. This suggests OFAC is concerned about advisory fees being structured as backdoor value transfers to the regime.

    What this signals in context: OFAC’s rapid release of new guidance and GLs represent only the U.S. side of what appears to be a fundamental re-ordering of the U.S.-Venezuela economic relationship. The 2026 GLs have been progressively opening sectors — oil (GL 46B, 50A, 52), minerals (GL 51A, 54, 55), all-sector negotiations (GL 56), and banking infrastructure (GL 57). GL 58 adds a new layer by opening the door to sovereign debt resolution advisory work. Combined with the simultaneous extension of GL 5W to block disorderly CITGO collateral seizures, it looks like OFAC is laying the procedural groundwork for an eventual managed debt restructuring — but keeping tight control by requiring separate authorization before anyone can actually execute a deal.

    How well-supported is this analysis? The factual claims about what the other GLs do are well-sourced from OFAC’s own publications, law firm analyses (Mayer Brown, Baker McKenzie, Leech Tishman, Paul Hastings, Herbert Smith Freehills), and OFAC FAQ pages. The interpretive claim — that GL 58 signals a managed path toward debt restructuring — is my inference from reading the licenses together. It’s a reasonable reading, but it’s speculation about policy intent, not established fact. I’d watch for Treasury press statements, State Department commentary, or new FAQs that might confirm or complicate that reading.

    I’d be really interested to see what consultants in our field think about this – I do notice Baker McKenzie’s name in there and that undoubtedly enhances the quality of the analysis, knitting together disparate elements that the day-to-day practitioner is too busy to contemplate.

    Got beef with this – or kudos? Let me know in the comments.

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  • May 5, 2026: OFAC issues a new (!) Venezuela-related General License

    This one is General License 58 (Authorizing Certain Services to the Government of Venezuela in Connection with Potential Debt Restructuring):

    venezuela_gl58Download

    My take: as opposed to finding an exception to prohibitions and then licensing them, this GL seems very much about “repairing” the Venezuelan state, which it undoubtedly has needed after so many years of mismanagement. Nice to see.

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  • May 4, 2026: Another OFAC Day, Another version of an OFAC GL (and the related FAQ)

    This time it’s Venezuela-related General License 5W (Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After June 19, 2026):

    venezuela_gl5wDownload

    And Frequently Asked Question 595 got an update, too:

    595. What does Venezuela-related General License 5W authorize?

    Answer

    The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity owned 50 percent or more by the GOV. One effect of subsection 1(a)(iii) is to require authorization before U.S. persons may engage in certain transactions regarding any equity interest in an entity owned 50 percent or more by the GOV. Subsequent to the issuance of E.O. 13835, OFAC received inquiries about how and whether subsection 1(a)(iii) of E.O. 13835 could affect the ability to enforce bondholder rights to the CITGO shares serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 percent bond. OFAC issued General License (GL) 5 on July 19, 2018, which removed E.O. 13835 as an obstacle to holders of the PdVSA 2020 8.5 percent bond gaining access to their collateral.

    General License 5 was replaced and superseded by General License 5A on October 24, 2019 with a delay in the effectiveness of the authorization in the general license. Since that date, OFAC has extended the delay in effectiveness multiple times. Most recently, OFAC issued General License 5W on May 4, 2026, which further delays the effectiveness of the authorization in GL 5 until June 19, 2026. Between October 24, 2019 and June 19, 2026 (the date the authorization in General License 5Wbecomes effective), there is no authorization in effect that licenses against subsection 1(a)(iii) of E.O. 13835 applicable to the holders of the PdVSA 2020 8.5 percent bond. As a result, during such period, transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited, unless specifically authorized by OFAC.

    To the extent an agreement may be reached on proposals to restructure or refinance payments due to the holders of the PdVSA 2020 8.5 percent bond, additional licensing requirements may apply. OFAC would encourage parties to apply for a specific license and would have a favorable licensing policy toward such an agreement.

    Date Updated: May 04, 2026

    Date Released

    January 20, 2022

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  • May 1, 2026: OFAC Iran-related Updates, Part 2: General Licenses, FAQs and another Alert… oh, my!

    First, Iran General License W (Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on May 1, 2026):

    iran_glwDownload

    and the new Frequently-Asked Question 1250:

    IRAN SANCTIONS

    1250. Are Iranian digital asset exchanges blocked under OFAC sanctions?

    Answer

    Yes. Executive Order (E.O.) 13599, as implemented by section 560.211(b) of the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR), blocks the property and interests in property of Iranian financial institutions. An Iranian financial institution is blocked pursuant to E.O. 13599 regardless of whether it is listed on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List). Iranian digital asset exchanges meet the regulatory definition of an “Iranian financial institution” as persons that engage in the business of activities described in section 560.324 of the ITSR.

    All property and interests in property of Iranian digital asset exchanges in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked pursuant to section 560.211 of the ITSR and must be reported to OFAC. See FAQ 160 for additional information regarding the sanctions implications of E.O. 13599. For additional information regarding the application of sanctions to digital assets, please see FAQs 559, 560, 561, 562, 563, 594, 646, and 647, as well as OFAC’s Sanctions Compliance Guidance for the Virtual Currency Industry.

    Date Released

    May 1, 2026

    and a new OFAC Alert (Hormuz News U Can Uz, as Stephen Colbert would say):

    20260501_hormuz_tolls_alertDownload

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  • April 29, 2026: I’m on E… OFAC Russia-related General License 131E, that is

    Here it is – “Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities”:

    russia_gl131eDownload

    And two amended FAQs:

    Russian Harmful Foreign Activities Sanctions

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

    OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”): GL 128C and GL 131E. 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 to extend the existing authorization until October 29, 2026.
    • 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, and 131E to extend the existing authorization until May 30, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

    GL 128C and GL 131E 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 128C and GL 131E. 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 128C and GL 131E 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 128C and GL 131E 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 128C and GL 131E. Similarly, non-U.S. persons may rely upon GL 128C and GL 131E 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 128C and GL 131E, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.

    Date Updated: April 29, 2026

    Updated on Apr 29, 2026

    Russian Harmful Foreign Activities Sanctions

    1224. What negotiations does Russia-related General License 131E authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets? 

    On October 22, 2025, OFAC designated Public Joint-Stock Company Oil Company Lukoil (Lukoil) to increase pressure on Russia’s energy sector and degrade Russia’s ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions. To support such divestments and further cut off funding to Russia, OFAC issued Russia-related General License (GL) 131E, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of LIG or any of LIG’s majority-owned subsidiaries. Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors. GL 131E expires on May 30, 2026.

    GL 131E does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset. Any contract entered into pursuant to GL 131E must expressly be made contingent upon the receipt of a separate authorization from OFAC. The goal of OFAC’s Russia sanctions is to place pressure on Moscow to end its war.

    As such, Treasury would evaluate any proposed sale of LIG based on factors that support U.S. national security and foreign policy objectives. OFAC expects that, at a minimum, the proposed transaction must: completely sever LIG’s ties with Lukoil; block any funds owed to Lukoil until sanctions are lifted by placing them in an account subject to U.S. jurisdiction; and not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps. Further, as a condition of any future license for effectuating a sale of LIG, OFAC expects that it will require persons purchasing LIG’s assets to seek OFAC review before further divestment of material LIG assets.

    OFAC may revoke GL 131E at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.

    Date Updated: April 29, 2026

    Updated on Apr 29, 2026

    And my apologies for the Blondie deep cut (from Plastic Letters, when I first started listening to them)…

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