The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 55F, “Authorizing Certain Services Related to Sakhalin-2;” and Russia-related General License 115D, “Authorizing Certain Transactions Related to Existing Civil Nuclear Energy Projects.”
In line with G7 efforts to reduce Russian revenues from energy, on January 10, 2025, Treasury issued a determination pursuant to Executive Order (E.O.) 14071 prohibiting petroleum services to Russia. See The Determination Pursuant to Sections 1(a)(ii), 1(b), and 5 of E.O. 14071, Prohibition on Petroleum Services (“the Petroleum Services Determination”). This determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, to any person located in the Russian Federation of petroleum services. The Petroleum Services Determination took effect at 12:01 a.m. eastern standard time on February 27, 2025. See FAQ 1217 for additional information.
OFAC expects to issue regulations defining petroleum services to include services related to the exploration, drilling, well completion, production, refining, processing, storage, maintenance, transportation, purchase, acquisition, testing, inspection, transfer, sale, trade, distribution, or marketing of petroleum, including crude oil and petroleum products, as well as any activities that contribute to Russia’s ability to develop its domestic petroleum resources, or the maintenance or expansion of Russia’s domestic production and refining. This would include services related to natural gas as a byproduct of oil production in Russia.
On October 22, 2025, OFAC issued GL 124A. In addition to continuing to authorize transactions prohibited by the Petroleum Services Determination related to the Caspian Pipeline Consortium (CPC) and Tengizchevroil, GL 124A also authorizes otherwise prohibited transactions related to the CPC and Tengizchevroil involving Lukoil, Rosneft, or any entity in which Lukoil or Rosneft owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. Additionally, on June 11, 2026, OFAC issued GL 55F, which extends authorizations for certain activities related to the Sakhalin-2 project that would otherwise be prohibited by the Petroleum Services Determination until December 18, 2026.
The Petroleum Services Determination does not apply to (1) any petroleum services related to isotopes derived from petroleum manufacturing that are used for medical, agricultural, or environmental purposes, such as Carbon-13; (2) certain covered services related to the maritime transport of crude oil and petroleum products of Russian Federation origin purchased at or below the relevant price cap; and (3) any service in connection with the wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person. See FAQ 1217 for additional information related to price cap related exclusions of the Petroleum Services Determination.
GL 115D generally authorizes certain transactions related to civil nuclear energy involving certain entities that are sanctioned pursuant to Executive Order 14024. Civil nuclear energy means the following activities when undertaken solely to maintain or support civil nuclear energy projects and operations initiated or under construction as of November 21, 2024: the extraction, production, refinement, conversion, enrichment, fabrication, transport, or purchase of uranium in any form; the production, generation, transmission, or exchange of nuclear power, fuel, or waste; and the operation of civil nuclear energy projects. However, GL 115D does not authorize, for instance, transactions involving certain sanctioned Russian financial institutions related to the development of new civil nuclear energy power plants after November 21, 2024.
Non-U.S. persons generally do not risk exposure to U.S. sanctions for engaging in transactions with blocked persons, including transactions related to existing civil nuclear energy as described in GL 115D, where those transactions would not require a specific license if engaged in by a U.S. person. See GL 132 for authorizations related to the Paks II civil nuclear power plant project in Hungary.
Treasury remains focused on counteracting activity that involves sanctions evasion or third-country support to Russia’s military-industrial base. At the same time, legitimate humanitarian activity and agricultural and medical trade are not the target of our sanctions. Accordingly, FFIs may continue to conduct or facilitate any transaction(s) or provide any service related to activities that are otherwise authorized or exempted under the Russian Harmful Foreign Activities Sanctions program. Foreign persons do not risk the imposition of sanctions for engaging in transactions authorized for U.S. persons under General Licenses issued under the Russian Harmful Foreign Activities Sanctions program.
FFIs may continue to rely on Treasury’s existing authorizations in place for transactions related to agricultural commodities, medicine, medical devices and related replacement parts, components, or software updates, the Coronavirus Disease 2019 (General License (GL) 6D), certain civil nuclear energy-related transactions (GLs 115D and 132), certain transactions in support of non-governmental organizations (GL 27), official business of third-country diplomatic or consular missions located in the Russian Federation (GL 20), certain transactions and official business of certain international organizations and entities by employees, grantees, or contractors thereof (31 CFR 587.510). Additionally, the importation or exportation of information or informational materials and transactions ordinarily incident to travel to or from any country are exempt under the International Emergency Economic Powers Act (IEEPA).
The determination made on February 24, 2023 pursuant to Executive Order (E.O.) 14024 authorizes sanctions on any person determined to operate or have operated in the metals and mining sector of the Russian Federation economy. Non-U.S. persons may also be exposed to sanctions for activities with persons blocked pursuant to E.O. 14024 (see FAQ 980), including persons blocked following a determination that such persons operate or have operated in the metals and mining sector.
However, OFAC does not intend to target persons for operating in the metals and mining sector where the provision of goods or services is solely for the safety and care of personnel, protection of human life, prevention of accidents or injuries, maintenance or repair necessary to avoid environmental or other significant damage, or activities related to environmental mitigation or remediation. Examples of such goods include personal protective equipment, safety devices, ventilation systems, and alarm systems; examples of such services include rescue and accident response services, cleaning, safety inspections, and services necessary for use of the goods described above.
In addition, non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under E.O. 14024 for engaging in transactions with blocked persons, including in the metals and mining sector, where those transactions would not require a specific license if engaged in by a U.S. person. For example, non-U.S. persons generally do not risk exposure to U.S. blocking sanctions for engaging in transactions in the metals and mining sector if such transactions would be authorized for U.S. persons by General License (GL) 115D (authorizing certain civil nuclear energy-related transactions) or by GL 6D (authorizing certain transactions related to the production, manufacturing, sale, transport, or provision of medicine or medical devices, including certain industrial isotopes used in nuclear medicine, among other things).
The Office of Foreign Assets Control (OFAC) encourages persons to connect with their financial institution regarding the status of any payment. In addition, persons with questions about engaging in or processing transactions related to GL 115D can contact the OFAC Compliance Hotline.
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 GL 13Q 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 13Q, 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 13Q, GL 14, GL 115D, and GL 132 continue to authorize against the Russia-related Sovereign Transactions Directive.
GLs 6D, 7A, or 115D, or 132 do not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of entities subject to the prohibitions of Directive 2 under E.O. 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive). Consequently, in order for a U.S. financial institution to engage in transactions authorized under these GLs (e.g., a funds transfer related to energy), all such funds transfers must be processed indirectly through a non-sanctioned, non-U.S. financial institution.
Examples of authorized and prohibited funds transfers under GLs 6D, 7A, 115D, and 132 include:
Payment from third-country originator
Authorized payment from third-country originator to beneficiary with an account at a sanctioned institution:
Prohibited payment from third-country originator to beneficiary with an account at a sanctioned institution:
Payment from U.S. originator
Authorized payment from U.S. originator to beneficiary with an account at a sanctioned institution:
Prohibited payment from U.S. originator to beneficiary with an account at a sanctioned institution:
In each of the above examples, the underlying funds transfer must be authorized under the applicable GL.
The Russia-related CAPTA Directive prohibits U.S. financial institutions from: (i) the opening or maintaining of a correspondent account or payable-through account for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive; and (ii) the processing of transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive. Please see the Russia-related CAPTA Directive for the definition of the terms “U.S. financial institution” and “foreign financial institution” for purposes of this directive. Please see FAQ 969 regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive.
Annex 1 to the Russia-related CAPTA Directive lists the foreign financial institutions determined to be subject to the prohibitions as of March 26, 2022. Foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, including the foreign financial institutions listed in Annex 1, can be found on the Office of Foreign Assets Control’s (OFAC) List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List). Relevant entries on the CAPTA List will denote when a foreign financial institution became subject to the prohibitions of the Russia-related CAPTA Directive, as well as when the prohibitions of the Russia-related CAPTA Directive come into effect with respect to that foreign financial institution.
The below table identifies the dates the prohibitions of the Russia-related CAPTA Directive take effect for (i) foreign financial institutions listed in Annex 1 to the Russia-related CAPTA Directive, and (ii) foreign financial institutions otherwise determined to be subject to its prohibitions and added to the CAPTA List.
Foreign Financial Institution Type
Relevant Sanctions Effective Date
Foreign financial institutions listed in Annex 1 to the Russia-related CAPTA Directive
12:01 a.m. eastern daylight time on March 26, 2022
Foreign financial institution otherwise determined to be subject to the prohibitions of the Russia-related CAPTA Directive
12:01 a.m. eastern time on the date that is 30 days after the date of such determination
U.S. financial institutions must close any correspondent or payable-through account maintained for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property, by the relevant effective date. Separately, as of the relevant effective date, U.S. financial institutions may not process transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property, and must reject such transactions unless exempt or authorized by OFAC.
Accordingly, after the relevant effective date, U.S. financial institutions must reject any transaction involving a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive or involving that foreign financial institution’s property or interests in property. This includes rejecting transactions related to any securities (including depositary receipts) issued by a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive, including secondary market trading. By virtue of the prohibition on the processing of transactions for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, U.S. financial institutions are also prohibited from engaging in transactions with a covered foreign financial institution in connection with the foreign financial institution’s role as a local custodian for depositary receipt issuances.
The Russia-related CAPTA Directive does not impose blocking sanctions and, thus, does not require U.S. financial institutions (or other U.S. persons) to block the assets of foreign financial institutions determined to be subject to the prohibitions of this directive. However, U.S. persons should be aware that foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive may also be subject to additional prohibitions under other sanctions authorities, such as additional directives under E.O. 14024 or E.O. 13662.
OFAC has issued several Russia-related general licenses (GLs)authorizing certain transactions involving the foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive, including:
GL 6D: authorizing transactions related to (1) the production, manufacturing, sale, or transport of agricultural commodities, agricultural equipment, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices; (2) the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19); or (3) ongoing clinical trials and other medical research activities;
GL 7A: authorizing overflight payments, emergency landings, and air ambulance services;
GL 27: authorizing transactions in support of nongovernmental organizations’ activities; and
GL 115D: authorizing certain transactions related to civil nuclear energy.
GL 132: authorizing certain transactions involving Paks II civil nuclear power plant.
On March 1, 2022, OFAC issued the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), which incorporate GL 5 in section 587.510 of the RuHSR.
For additional information, please see FAQs 977, 978, 979, 981, 982 and 990.
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.
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.
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):
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.
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.
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.
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
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):
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.
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:
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.
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.
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.
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.
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.
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.
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.
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.
