First, the Determination:
Next, the revocation/suspension of exemptions and general licenses:
Next, General License AA (Authorizing Certain Activities Involving La Nivernaise De Raffinage SAS):
and General License BB (Authorizing the Wind Down of Certain Transactions Previously Authorized Under the Iranian Transactions and Sanctions Regulations):
and, finally, an OFAC Alert (Sanctions Risks of Iranian Demands for Strait of Hormuz Passage):
On Friday, OFAC issues Venezuela GL 61 (Authorizing the Supply of Certain Items and Services to Venezuela Related to Telecommunications):
and GL 62 (Authorizing Negotiations of and Entry Into Contingent Contracts for Investment in the Telecommunications Sector of Venezuela):
and, for good measure, FAQ 1266:
1266. What activities does Venezuela General License (GL) 61 authorize?
Answer
GL 61 authorizes transactions ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the installation, maintenance, refurbishment, repair, upgrade, operation, or support of telecommunications in Venezuela, including transactions involving the Government of Venezuela, including but not limited to the Comisión Nacional de Telecomunicaciones (CONATEL), Compania Anonima Nacional Telefonos de Venezuela (CANTV), and Movilnet.
For purposes of GL 61, telecommunications includes data, telephone, internet connectivity, radio, television, news wire feeds, and similar services, regardless of the medium of transmission, including transmission by satellite or through submarine cables.
Authorized transactions include: processing payments and arranging shipping, including air freight, logistics, warehousing, insurance, and delivery services; interconnection and roaming agreements; capacity or infrastructure leases; and the laying, maintenance, repair, refurbishment, upgrade, security, operation, or support of submarine cables and other telecommunications infrastructure or equipment; and the provision, licensing, renewal, maintenance, or support of related software, systems, and services, including software updates and network-support services. The provision of other financial services for the refurbishment, repair, upgrade, operation, or support of telecommunications in Venezuela would also be authorized to the extent ordinarily incident and necessary to the authorized telecommunications-related activity and provided that it does not involve debt swaps or other payment terms prohibited by GL 61.
Examples of transactions authorized by GL 61 include those ordinarily incident and necessary to the provision of:
- telecommunications equipment and network infrastructure, including broadband access equipment, components, and spare parts;
- telecommunications capacity or infrastructure through leases, including fiber-optic pairs and satellite bandwidth;
- international telecommunications connectivity, including IP transit;
- telecommunications-related:
- software, including licensing, renewals, updates, maintenance, and technical or vendor support;
- cloud services;
- data storage and backup systems, network monitoring and automation platforms;
- customer billing systems; and
- servers and other computing systems used to support telecommunications.
Notably, GL 61 does not authorize:
- payment terms that are not commercially reasonable, involve debt swaps or payments in gold, or are 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 or organized under the laws of Russia, Iran, North Korea, Cuba, or the People’s Republic of China, or an entity owned or controlled, directly or indirectly, by or in a joint venture with such a person;
- the unblocking of property blocked pursuant to the Venezuela Sanctions Regulations;
- transactions involving blocked vessels; or
- the formation of new joint ventures or other entities in Venezuela to develop or invest in the telecommunications sector.
Date Released
August 21, 2026
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):
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
OFSI has Amended and Extended the Lukoil International General Licence and the Lukoil Bulgaria General Licence
OFSI has published amendments to the Lukoil International General Licence (INT/2025/8031092) and the Lukoil Bulgaria General Licence (INT/2025/7895596).
Both General Licences include a notification requirement for any Entity using the amended licences. Entities relying on the amended General Licences must notify OFSI when they first use the licence and provide their current contact details. Entities that begin using the licences on or after 12 August 2026 must notify OFSI within 14 days of first use. Entities already relying on the licence when the requirement takes effect must notify OFSI within 14 days of 12 August 2026. This is a one-off notification requirement unless contact details change. Submission of a notification does not constitute confirmation by HM Treasury that the activity is permitted under the licences.
The Lukoil International General Licence (INT/2025/8031092) has been extended until 26 February 2027.
The Lukoil Bulgaria General Licence (INT/2025/7895596) has been extended until 29 October 2026.
OFSI: Amended the Russian Oil Exempt Projects General Licence
OFSI has published an amended Russian Oil Exempt Projects General Licence INT/2025/5635700.
The General Licence was amended to include the Kurdistan Export Pipeline until 14 October 2027.
Any persons intending to use General Licence INT/2025/5635700 should consult the copy of the Licence for full details of the permissions and usage requirements.
Here’s the Publication Notice:
and the General Licence:
Yes, OFAC’s Venezuela GL 5 is up to the Y revision:
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
The prompt:
Speak to the following: The Federal Register vs. the OFAC website: which one is legally operative, and what about time gaps between the two?
The response:
The Federal Register is legally operative for OFAC actions that require notice-and-publication; the OFAC website is not a legal instrument.
The distinction turns on the type of action. For designations under most sanctions programs, OFAC’s legal authority to add a party to the SDN List derives from the underlying statute and executive order, and the designation becomes effective when the Director (or Secretary) signs the determination, not when it appears anywhere. OFAC then publishes the SDN List update on its website, typically the same day, and follows with a Federal Register notice, sometimes days or weeks later.
For rules that carry legal force in their own right, the Federal Register is authoritative. Amendments to the sanctions regulations in Title 31 CFR, general licenses that OFAC chooses to codify, and formal rulemakings take legal effect on the date and terms stated in the Federal Register. The Federal Register text is the official version; if the website and the published notice ever diverged, the Federal Register controls.
On the time gaps: the practical answer for compliance purposes is that OFAC treats a designation as effective from the moment of the action, and the SDN List posting on the website is the operational trigger the industry screens against. The Federal Register notice is a legal formality that documents the action and satisfies publication requirements, but the absence of a same-day Federal Register notice does not delay the legal effect of a designation. A party added to the SDN List on Tuesday is blocked as of Tuesday, even if the corresponding Federal Register notice does not run until the following week. The prohibition attaches to the U.S. person’s dealings with blocked property, and OFAC’s position is that the obligation exists once the property interest is blocked, independent of publication timing.
Two nuances worth flagging. First, some due-process and constructive-notice questions have been litigated, and courts have generally accepted that public availability of the SDN List provides adequate notice, which is why the website posting matters practically even though it is not the legal instrument. Second, the effective date stated in a Federal Register notice may differ from the website posting date; where a specific legal deadline or wind-down period runs from an effective date, read that date from the Federal Register text rather than inferring it from when the website was updated.
If you want, I can pull the specific statutory publication requirements (for example, the IEEPA and APA provisions and any program-specific notice language) to tighten the citations.
Today, OFAC issued Russian-related General License 131H:
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:
As a program new to GLs (at least recently), we have GL 2 (Authorizing the Wind Down of Transactions Involving CEIBA Investments Limited):
GL 3 (Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, CEIBA Investments Limited):
and GL 4 (Authorizing Transactions for Third-Country Official Missions in Cuba):
Note: Part 2 is being uploaded prior to Part 1 – due to the size of the update, Claude is taking quite a while making the draft post.
