Mr. Sanctions

Category: New General License Version

  • June 10, 2026: OFAC Update, Part 2: New versions of 7 Venezuela General Licenses, and 2 new Frequently Asked Questions

    Here’s what OFAC said:

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

    Additionally, OFAC is issuing two Venezuela-related Frequently Asked Questions, FAQs 1259 and 1260.

    Let’s go backward this time – here are the FAQs:

    1260. Does the requirement in certain Venezuela General Licenses (e.g., 46C, 47A, 48B, 50B, 51B, 52A, and 54A) that the terms of contracts be construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States mean that U.S. law must govern all aspects of the underlying activity? 

    No.  Certain Venezuela general licenses (GLs) require that any contract for transactions authorized by the GL with the Government of Venezuela or certain other covered entities (e.g., Petróleos de Venezuela, S.A. in GL 52A or CVG Compañía General de Minería de Venezuela CA in GL 51B) specify that the terms of the contract be construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States. The GLs also require dispute resolution proceedings relating to the contract or its breach to occur in the United States, the United Kingdom, France, or Singapore. If the parties agree to submit their dispute to arbitration, the procedural rules applicable are those rules agreed by the parties, or the rules of internationally recognized institutions or the rules of the seat of arbitration.

    This requirement means that the laws of a state or other jurisdiction within the United States must govern questions of contract law between the parties relating to the contract, including interpretation, contractual performance obligations, breach, contractual remedies, payment obligations, termination, validity, assignment or novation, and enforceability of the contract.

    The requirement permits the inclusion of contract terms that recognize that certain aspects of the underlying activity in Venezuela may be subject to applicable Venezuelan law and regulations, including laws and regulations governing the exercise of Venezuela’s sovereign regulatory authority, administrative permits and licenses, concessions, labor, environmental, health and safety, and other mandatory regulatory requirements.

    Released on Jun 10, 2026

    Venezuela Sanctions

    1259. Are private and commercial flights authorized to arrive in and depart from airports in Venezuela, and can they receive ground services in-country? 

    Yes. Venezuela-related General License (GL) 30B authorizes U.S. persons to engage in all transactions involving the Government of Venezuela (GOV), including its agencies and instrumentalities like the Instituto Nacional de Aeronáutica Civil (INAC) and Instituto Nacional de los Espacios Aquaticos (INEA), that are ordinarily incident and necessary to the operation or use of airports in Venezuela.

    Transactions ordinarily incident and necessary to the operation or use of airports in Venezuela include but are not limited to: the provision of baggage and ground handling services; safety and security services; airport operational services; air navigation and overflight services; fuel and into-plane services; and the payment of aeronautical, customs, immigration, and other government-imposed fees and taxes. Please see FAQ 1236 for additional information on GL 30B’s authorizations.

    GL 30B does not authorize transactions involving blocked persons other than (i) INEA, or (ii) GOV persons blocked solely pursuant to E.O. 13884, including INAC.

    Additionally, Venezuela-related GL 33 authorizes the receipt of, and payment for, services involving the GOV related to overflights and emergency landings in Venezuela. It also authorizes transactions necessary to provide air ambulance and related medical services, including medical evacuation.

    GL 33 does not authorize transactions involving persons identified on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) or owned 50 percent or more by persons identified on the SDN List.

    Generally, non-U.S. persons do not risk exposure to U.S. sanctions for engaging in transactions authorized for U.S. persons, including engaging in transactions authorized pursuant to GL 30B or GL 33. Additionally, U.S. sanctions programs issued pursuant to the International Emergency Economic Powers Act (IEEPA), including the Venezuela Sanctions Regulations, do not generally prohibit transactions ordinarily incident to travel to or from any country.

    Released on Jun 10, 2026

    and the GLs:

    venezuela_gl46cDownload
    venezuela_gl47aDownload
    venezuela_gl48bDownload
    venezuela_gl50bDownload
    venezuela_gl51bDownload
    venezuela_gl52aDownload
    venezuela_gl54aDownload

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  • May 28, 2026: OFAC Update 2, Part 2: The Amended Russia GL and FAQs

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

    russia_gl131fDownload

    and amended Frequently-Asked Questions 1224:

    1224. What negotiations does Russia-related General License 131F 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) 131F, 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 131Fexpires on June 28, 2026.

    GL 131F 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 131F 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 131F 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: May 28, 2026

    Date Released

    November 19, 2025

    and 1225:

    1225. What activities do Russia-related General License 128C and General License 131F 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 131F. 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, 131E, and 131F to extend the existing authorization until June 28, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

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

    Date Updated: May 28, 2026

    Date Released

    December 4, 2025

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  • 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 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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