Mr. Sanctions

Category: New General License Version

  • September 16, 2026: OFAC Update Part 2: Venezuela General License 5 versions goes to Z, and the amended FAQ

    GL 5 has been updated to GL 5Z:

    venezuela_gl5zDownload

    And Frequently Asked Question 595 got updated, too:

    595. What does Venezuela-related General License 5Z 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    General License 5 was replaced and superseded by General License 5A on October 24, 2019 with a delay in the effectiveness of the authorization in the general license.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 5Z on September 16, 2026, which further delays the effectiveness of the authorization in GL 5 until November 5, 2026. Between October 24, 2019 and November 5, 2026 (the date the authorization in General License 5Z becomes 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: September 16, 2026

    Date Released

    January 20, 2022

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  • September 14, 2026: OFAC Update, Part 2: New Version of Venezuela GL and updated FAQ

    Today, OFAC updated Venezuela-related General License 52C (Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.):

    venezuela_gl52cDownload

    Additionally, Frequently Asked Question 1245 was updated:

    1245. What activities are authorized by Venezuela General License (GL) 52C, “Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.”?

    Answer

    GL 52C authorizes, subject to its conditions and exclusions, transactions prohibited by Executive Orders (E.O.s) 13884 or 13850 with Petróleos de Venezuela, S.A. (PdVSA) and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, “PdVSA Entities”), by established U.S. entities. Transactions authorized by GL 52C include activities related to:

    • the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan oil or petroleum products of Venezuelan-origin oil and petroleum products;
    • the provision to Venezuela of diluent, goods, services, and technologies necessary for exploration, development, or production activities in the oil, gas, or petrochemical products sectors;
    • entry into new investment contracts for exploration, development, or production activities in the oil, gas, or petroleum products sectors of Venezuela;
    • the formation of new joint ventures or other entities in Venezuela related to such activities; and
    • all transactions ordinarily incident and necessary to such activities, including the performance of commercial, legal, technical, safety, and environmental due diligence and assessments related to the foregoing.

    GL 52C also authorizes individuals blocked pursuant to the Venezuela Sanctions Regulations (VSR) to execute and sign contracts authorized by GL 52C in their official capacity as officers, employees, or authorized representatives of PdVSA or PdVSA Entities.

    Notably, GL 52C does not authorize transactions that would otherwise be prohibited by the VSR and associated Executive Orders, including E.O. 13808 and E.O. 13835, such as:

    • transactions related to bonds and debt issued by PdVSA and its subsidiaries, including settlement of such bonds and debt;
    • transactions involving equity interest in PdVSA and its subsidiaries, including the sale, transfer, assignment, or use as collateral of equity interests in PdVSA and its subsidiaries by the Government of Venezuela;
    • transactions involving the transfer of equity interest in PDV Holding, CITGO Holding, or CITGO Petroleum Corp.;
    • transactions to affect or alter the governance of PDV Holding, Inc., Citgo Holding, Inc., or CITGO Petroleum Corporation, including the appointment, removal, or replacement of any director, officer, or other corporate governance official; or
    • transactions involving any other individuals or entities on the List of Specially Designated Nationals and Blocked Persons.

    GL 52C also does not authorize:

    • transactions that are not on commercially reasonable terms;
    • payment in gold or the use of debt swaps;
    • payments denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
    • any transaction involving a person located in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled by or in a joint venture with such persons;
    • transactions involving an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China;
    • the unblocking of any property blocked pursuant to the VSR; or
    • any transaction involving a blocked vessel.
    Date Updated: September 14, 2026

    Date Released

    March 18, 2026

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  • September 3, 2026: OFAC Update, Part 2: new version of Cuba General License 4

    This is GL 4A (Authorizing Transactions for Third-Country Diplomatic and Consular Missions in Cuba):

    cuba_gl4aDownload

    What are the important differences? Let Claude explain:

    Paragraph (c) – restructured and narrowed:

    • GL 4 had two exclusions: (c)(1) barred financial transfers to any blocked person except for taxes, fees, import duties, or permits/licenses/public utility services tied to paragraph (a) transactions; and (c)(2) barred unblocking of any property.
    • GL 4A drops (c)(1) entirely. The sole remaining exclusion is the unblocking prohibition (what was (c)(2)), now written as the whole of (c).

    Practical effect (my reading, not stated in the text itself): By removing (c)(1)’s narrow carve-out, GL 4A appears to broaden the scope of authorized financial transfers to blocked persons. Under GL 4, such transfers were confined to taxes, fees, import duties, and permit/license/utility payments tied to official-business transactions. Under GL 4A, that specific limitation is gone – transactions otherwise meeting the “ordinarily incident and necessary” standard in (a) or (b) are no longer subject to that narrower financial-transfer restriction. The only thing GL 4A still expressly withholds is unblocking of property. 

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  • September 2, 2026: Finally – OFAC reminds you of the ARBP filing, issues new versions of Venezuela GLs, and amends a related FAQ

    Reminder to file the 2026 Annual Report of Blocked Property; Issuance of Amended Venezuela-related General Licenses and Frequently Asked Question

    09/02/2026

    Recent Actions Body

    On July 1, 2026, the Office of Foreign Assets Control (OFAC) issued a recent actions notice, reminding U.S. persons holding blocked property as of June 30, 2026, to file an Annual Report of Blocked Property (ARBP) no later than September 30, 2026. Failure to file the ARBP by September 30 may lead to an enforcement referral.

    For additional information, please review OFAC’s Guidance on Filing the 2026 Annual Report of Blocked Property.

    Additionally, OFAC is issuing Venezuela-related General License 51D, “Authorizing Certain Activities Involving Venezuelan-Origin Coal or Minerals, Including Gold;” Venezuela-related General License 54C, “Authorizing the Supply of Certain Items and Services for Coal or Minerals Operations in Venezuela;” and Venezuela-related General License 55A, “Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela’s Coal or Minerals Sectors.”

    Lastly, OFAC has amended one Venezuela-related Frequently Asked Question, FAQ 1247.

    The guidance:

    arbp_guidance_2026Download

    GL 51D:

    venezuela_gl51dDownload

    GL 54C:

    venezuela_gl54cDownload

    GL 55A:

    venezuela_gl55aDownload

    and the FAQ:

    1247. Do non-U.S. persons face sanctions risk for engaging in transactions authorized by General Licenses (GL) 46D, 51D, and 52B? 

    No, provided that non-U.S. persons comply with certain conditions outlined in GLs 46D, 51D, and 52B as described below. Subject to certain conditions, GLs 46D, 51D, and 52B authorize established U.S. entities to engage in certain transactions involving Petróleos de Venezuela, S.A. (PdVSA), as well as certain transactions with the Government of Venezuela, including Carbones del Zulia S.A. (Carbozulia), PdVSA, or CVG Compania General de Mineria de Venezuela CA (Minerven) that are ordinarily incident and necessary to, among other activities, the exportation, sale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin oil, petrochemical products, minerals (including gold), or coal. Generally, non-U.S. persons do not risk exposure to U.S. sanctions for engaging in transactions authorized under GLs 46D, 51D, and 52B — such as transacting with PdVSA or importing Venezuelan-origin oil, petrochemical products, minerals, or coal, into a third country — provided that:

    • The non-U.S. entity was organized under the laws of a third country on or before January 29, 2025;
    • Any monetary payment to a blocked person, excluding payments for local taxes, permits, or fees, is made into the Foreign Government Deposit Funds, as specified in Executive Order 14373 of January 9, 2026, or any other account as instructed by the U.S. Department of the Treasury;
    • The payment terms are commercially reasonable;
    • The payment terms do not involve debt swaps, and are not denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
    • The transaction does not involve a person located in or organized under the laws of the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled, directly or indirectly, by or in a joint venture with such persons;
    • The transaction does not involve an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China;
    • The transaction does not involve a blocked vessel; and
    • With respect to GL 51D, the transaction does not involve the processing or refining of Venezuelan-origin coal or minerals, including gold, in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or the People’s Republic of China.

    These conditions are designed to ensure that transactions involving the Government of Venezuela, including Carbozulia, PdVSA, Minerven, or Venezuelan-origin oil, petrochemical products, minerals, or coal occur through legitimate and authorized channels, consistent with efforts to restore prosperity, safety, and security to Venezuela. Non-U.S. persons who continue to transact with PdVSA or Minerven, or import Venezuelan-origin oil, petrochemical products, minerals including gold, or coal, without complying with the above conditions risk being designated themselves, including for providing financial, material, or technological support to blocked persons, being responsible for or complicit in a transaction involving deceptive practices or corruption and the Government of Venezuela, or operating in the gold or oil sectors of the Venezuelan economy.

    Please note that GL 52B contains additional restrictions on engaging in certain transactions prohibited by other Venezuela-related Executive orders, such as transactions related to bonds and debt issued by PdVSA, as well as on the entry into a settlement agreement or the enforcement of any lien, judgment, or other order through execution, garnishment, or other judicial process purporting to transfer or otherwise alter or affect property or interests in property of any persons blocked pursuant to the Venezuela Sanctions Regulations.

    Please see FAQ 1226 for the definition of “Venezuelan-origin oil,” which includes petroleum products.

    Please see FAQ 1232 for what OFAC considers “commercially reasonable terms.”

    Please see FAQ 1239 for information on how to make authorized payments to the Foreign Government Deposit Funds, as specified in E.O. 14373.

    Date Updated: September 02, 2026

    Updated on Sep 02, 2026

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  • August 27, 2026: Got Wite-Out? OFAC issues new versions of 8 Venezuela General Licenses, issues 2 new FAQs, amends 2, and archives 1 – and Claude explains the changes

    Issuance of Amended Venezuela-related General Licenses and Associated Frequently Asked Questions

    Release Date

    08/27/2026

    Recent Actions Body

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Venezuela-related General License 46D, “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products;” Venezuela-related General License 47B, “Authorizing the Sale of U.S.-Origin Diluents to Venezuela;” Venezuela-related General License 48C, “Authorizing the Supply of Certain Items and Services to Venezuela;” Venezuela-related General License 50C, “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities;” Venezuela-related General License 51C, “Authorizing Certain Activities Involving Venezuelan-Origin Minerals, Including Gold;” Venezuela-related General License 52B, “Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.;” Venezuela-related General License 54B, “Authorizing the Supply of Certain Items and Services for Minerals Operations in Venezuela;” and Venezuela-related General License 61A, “Authorizing the Supply of Certain Items and Services to Venezuela Related to Telecommunications.”

    Additionally, OFAC is issuing two new Venezuela-related Frequently Asked Questions (FAQs 1267 and 1268), amending two Venezuela-related Frequently Asked Questions (FAQs 1233 and 1244), and archiving FAQ 1260.

    Claude explains the difference:

    What’s new is that OFAC fully removed the separate governing-law requirement, the clause requiring contract terms to be “construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States.” So the two conditions that used to travel together (US governing law + dispute resolution venue) have been decoupled, and only the dispute-resolution piece survives. That’s the substantive change behind your two new FAQs:

    • FAQ 1267 (new): Asks whether the amended GLs still require a choice-of-law provision. Answer: no, effective Aug 27, 2026. OFAC states the rationale as responding to “investment-related reforms made by the GOV since January 2026.” It doesn’t name Venezuela’s Hydrocarbons Law amendment specifically, so connecting the two is my inference based on outside reporting, not something OFAC states in the FAQ itself.
    • FAQ 1268 (new): Confirms the dispute-resolution-venue requirement itself is untouched, and adds a clarifying line that the requirement “relates to the jurisdiction in which dispute resolution proceedings must occur, rather than the law governing the underlying contract.”

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  • August 26, 2026: OFAC Update, Part Two: Russia (new version) and Counter-Terror (new) General Licenses

    First, Counter-Terrorism GL 36 (Authorizing the Wind Down of Transactions Involving Autistici Inventati):

    ct_gl36Download

    Second, Russia GL 104B (Authorizing Transactions Related to Imports of Certain Diamonds Prohibited by Executive Order 14068):

    russia_gl104b_0Download

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  • August 20, 2026: OFAC Update, Part 2: New version of Russian GL131, and 3 amended FAQs (2 Russian, 1 Cuban)

    While Claude is chugging through the massive update today (a press chart, 2 Treasury PRs, 3 State PRs, and a fact sheet), I’m going to post the other part…

    First, Russia-related General License 131I (Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities):

    russia_gl131iDownload

    And OFAC updated 2 related Russian Frequently-Asked Questions again – 1224:

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

    Answer

    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) 131I, 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 131I expires on September 19, 2026.

    GL 131I 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 131I 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 131I 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: August 20, 2026

    Date Released

    November 19, 2025

    and 1225:

    1225. What activities do Russia-related General License 128C and General License 131I authorize 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 128C and GL 131I. 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, GL 131E, GL 131F, GL 131G, GL 131H, and GL 131I, to extend the existing authorization until September 19, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

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

    Date Updated: August 20, 2026

    Date Released

    December 4, 2025

    as well as Cuba FAQ 1265:

    1265. On August 20, 2026, the Department of State designated the Ministry of Construction of Cuba (MICONS) pursuant to E.O. 14404.  Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with MICONS?

    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 wind down of transactions involving MICONS, or any entity in which MICONS owns, directly or indirectly, a 50 percent or greater interest, through September 19, 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 MICONS, or any entity in which MICONS owns, directly or indirectly, a 50 percent or greater interest, before September 19, 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 MICONS, including in connection with a non-U.S. person’s wind down of activities with MICONS, absent OFAC authorization. Relevant authorizations may include humanitarian-related transactions authorized under the CACR in subpart E of part 515 and under E.O. 14404 via General License (GL) 1.  For additional information on GL 1, see FAQ 1253. 

    Date Released

    August 20, 2026

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  • August 3, 2026: Y?

    Yes, OFAC’s Venezuela GL 5 is up to the Y revision:

    venezuela_gl5yDownload

    and there is an updated FAQ 595, too

    595. What does Venezuela-related General License 5Y 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 5Y on August 3, 2026, which further delays the effectiveness of the authorization in GL 5 until September 17, 2026. Between October 24, 2019 and September 17, 2026 (the date the authorization in General License 5Y becomes 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: August 03, 2026

    Date Released

    January 20, 2022

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  • July 24, 2026: OFAC Update, Part 2: New Version of Russian GL, amended Russia and Venezuela FAQs, and final rule to update and correct CFR

    Today, OFAC issued Russian-related General License 131H:

    Russia_gl131HDownload

    and amended related Frequently Asked Questions 1224:

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

    Answer

    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) 131H, 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 131H expires on August 22, 2026.

    GL 131H 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 131H 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 131H 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: July 24, 2026

    Date Released

    November 19, 2025

    and 1225:

    1225. What activities do Russia-related General License 128C and General License 131Hauthorize 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 128C and GL 131H. 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, GL 131E, GL 131F, GL 131G, and GL 131H, to extend the existing authorization until August 22, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

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

    Date Updated: July 24, 2026

    Date Released

    December 4, 2025

    as well as Venezuela FAQ 1239:

    1239. Where can I find the account information to make authorized payments to the Foreign Government Deposit Funds deposit account, as specified in Executive Order 14373?

    Answer

    To obtain payment account information for payments to the Foreign Government Deposit Funds deposit account established consistent with Executive Order (E.O.) 14373, “Safeguarding Venezuelan Oil Revenue for the Good of the American and Venezuelan People,” and referenced in certain Venezuela General Licenses, depositors must first email the official point of contact for the deposit account at: DepositorInquiries@state.gov. Potential depositors that fail to contact this email inbox and provide the requested transaction details may have their deposits rejected. Potential depositors should be prepared to provide all relevant transaction details, including the following, as appropriate:

    • Full legal names and addresses of corporate depositor and all contract parties (provide subsidiary information, as applicable);
    • Detailed description of the underlying contract or obligation, including the purpose and nature of the payment (include information on the type of product and amount purchased and/or sold);
    • Date of sale and copies of the corresponding invoice(s), contract number(s), and any relevant reference identifiers;
    • Total payment amount, currency, and proposed payment date(s);
    • Identification of the license authorizing the transaction;
    • Copies of any other transaction record(s) to validate the deposit; and
    • Primary point of contact for any follow-up questions, including name, title, telephone number, and email address.

    Once the Department of State has provided payment account information and the deposit has been made and accepted, the depositor will receive a confirmation email acknowledging the deposit, which can be used to inform all contract parties involved in the transaction.

    Date Updated: July 24, 2026

    Date Released

    March 4, 2026

    Finally, OFAC issued a new final rule:

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is adopting a final rule to update website and contact information in certain parts of the Code of Federal Regulations (CFR). Additionally, OFAC is amending one CFR part to update general licenses authorizing payments for legal services from funds originating outside the United States to replace the reporting requirement in the general license with a recordkeeping requirement and correcting typographical errors in two CFR parts. OFAC is also updating a part of 31 CFR chapter V to correct an erroneous cross-reference.

    Here’s the final rule:

    fr_Updating Website and Contact Information, and Authorizations for Payments for Legal ServicesDownload

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  • July 8, 2026: Another 3 months for OFAC Russia-related GL 13… and 2 updated FAQs

    Today, OFAC issued Russia-related General License 13R:

    russia_gl13rDownload

    and updated 2 Frequently Asked Questions:

    1118. As of December 2022, the Government of the Russian Federation may require a so-called “exit tax” payment prior to the divestment of assets located in the Russian Federation, potentially requiring transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation. Do U.S. sanctions prohibit the payment of this so-called “exit tax”? Does Russia-related General License (GL) 13R authorize transactions that involve the payment of this exit tax? 

    Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive), prohibits the following activities by U.S. persons: any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities (collectively, “Directive 4 entities”). As noted in FAQ 1002, this includes both direct and indirect transactions.

    OFAC issued the Russia-related Sovereign Transactions Directive with the explicit aim of preventing the Government of the Russian Federation from leveraging these institutions and their holdings of international reserves in ways that would undermine the impact of U.S. sanctions. Information currently available to OFAC suggests so-called “exit taxes” imposed by the Government of the Russian Federation involve payments to Directive 4 entities. Consequently, U.S. persons whose divestment from the Russian Federation will involve the payment of such an exit tax require a specific license from OFAC prior to the payment of such tax, unless otherwise authorized by OFAC.

    GL 13R authorizes U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications involving Directive 4 entities that would otherwise be prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation. Payment of exit taxes is not considered ordinarily incident and necessary to day-to-day operations in the Russian Federation and, thus, is not authorized under GL 13R.

    Therefore, U.S. persons whose divestment of assets in the Russian Federation will involve a payment of such an “exit tax” should seek a specific license from OFAC. Such persons may submit a request for a specific license with OFAC’s Licensing Division online at https://ofac.treasury.gov/ofac-license-application-page. License applications related to these payments should include information regarding the amount of the exit tax, the amount of ongoing taxes that would otherwise be paid to the Government of the Russian Federation should divestment not occur, the impact of a failure to pay the tax on the employees of the exiting company, the specific economic activity in Russia of the exiting company, and the impact on the Russian Federation of the divestment. OFAC will expedite its review of such requests, which will be evaluated on a case-by-case basis.

    While OFAC is aware that the Commission established by the Russian Federation to review such divestments may include individuals from entities subject to the Russia-related Sovereign Transactions Directive or individuals listed on the Specially Designated Nationals and Blocked Persons List, U.S. persons do not need to seek authorization from OFAC for their Russian buyers to submit an application to the Commission regarding a divestment transaction.

    Date Updated: July 08, 2026

    Updated on Jul 08, 2026

    Russian Harmful Foreign Activities Sanctions

    999. What authorizations exist for entities subject to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive)? 

    OFAC issued Russia-related General License (GL) 132 to authorize transactions involving the Paks II civil nuclear power plant project in Hungary, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive.

    OFAC issued Russia-related General License (GL) 115D to authorize civil nuclear energy-related transactions, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive.

    OFAC issued GL 13R to authorize U.S. persons to pay taxes, fees, or import duties and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation. For further information on the types of transactions authorized by GL 13R, see FAQ 1118.

    OFAC also issued GL 14, authorizing certain transactions involving any Directive 4 entity where the Directive 4 entity’s sole function in the transaction is to act as an operator of a clearing and settlement system. GL 14 does not authorize any transfer of assets to or from any Directive 4 entity, or any transaction where a Directive 4 entity is either a counterparty or beneficiary to the transaction. In addition, GL 14 does not authorize any debit to an account on the books of a U.S. financial institution of any Directive 4 entity. See FAQ 1003.

    Note that GL 13R, GL 14, GL 115D, and GL 132 continue to authorize against the Russia-related Sovereign Transactions Directive.

    Date Updated: July 08, 2026

    Updated on Jul 08, 2026

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