On Thursday, OFAC issued Russia-related General License 134 (,Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 12, 2026):
That being said, check out the large number of impacted sanctions regulations and Executive Orders – hoo-boy!
Published 11 March 2026
Introduction
The Export Control Joint Unit (ECJU) has updated the open general export licence (OGEL) military goods: collaborative project Typhoon has been updated to include Turkey as a permitted destination.
An additional condition has been added to this OGEL requiring the licence reference in the form ‘GBOGE 20XX/XXXXX’ to be entered onto the UK’s customs declarations system.
Registration requirements
Exporters must ensure they are registered on SPIRE, ECJU’s export licensing system, for the updated OGELs. Existing registrations will carry over, but exporters should review conditions carefully.
Contact ECJU
General queries about strategic export licensing
Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DYEmail exportcontrol.help@businessandtrade.gov.uk
Telephone 020 7215 4594
On Friday, OFAC issued Venezuela-related General License 51 (Authorizing Certain Activities Involving Venezuelan-Origin Gold):
On Thursday, OFAC issued Russia-releated General License 133 (Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 5, 2026 to India):
and amended Venezuela-related Frequently-Asked Question 1238:
1238. Would OFAC approve the resale of Venezuelan origin oil to Cuba?
Answer
In accordance with the United States’ support and solidarity for the Cuban people, OFAC would implement a favorable licensing policy toward specific license applications seeking authorization for the resale of Venezuelan-origin oil for use in Cuba. To qualify for this favorable licensing policy, the requested transactions would need to be consistent with the terms and conditions of Venezuela General License (GL) 46A, though applicants need not necessarily have an established U.S. entity and the limitations in GL 46A with respect to Cuba would not apply. This favorable licensing policy is directed towards transactions that support the Cuban people, including the Cuban private sector (e.g., exports for commercial and humanitarian use in Cuba). Consistent with applicable U.S. law and policy, transactions involving, or for the benefit, of any persons or entities associated with the Cuban military, intelligence services, or other government institutions, including entities listed on the U.S. State Department’s Cuba Restricted List, see 31 C.F.R. 515.209, as well as any Cuban-owned financial institutions, would not be covered by this favorable licensing policy (collectively, the “excluded parties”).
Parties seeking a license under this policy must implement measures to ensure that no subsequent transactions related to the Venezuelan-origin oil involve or benefit, either directly or indirectly, the excluded parties. These measures should include provisions in sale or resale agreements prohibiting any direct or indirect participation by the excluded parties in any present or future transaction related to the Venezuelan-origin oil, as well as requirements that any present or future financial transactions involving the sale or resale of the Venezuelan-origin oil are routed through a financial institution based in the United States, or otherwise do not involve transactions routed through financial institutions associated with, or controlled by, the excluded parties.
As a reminder, the U.S. Department of Commerce primarily regulates the export or reexport of U.S.-origin oil to Cuba, as well as all other items subject to the Export Administration Regulations (EAR, 15 C.F.R. parts 730-774). Treasury’s Cuban Assets Control Regulations generally authorize U.S. persons to engage in transactions ordinarily incident to the export of oil from the United States to Cuba, or the reexport of U.S.-origin oil from a third country to Cuba, where that export or reexport has been authorized by the Commerce Department. See 31 C.F.R. 515.533(a). This authorization applies to transactions covered by applicable Commerce Department license exceptions, including License Exception Support for the Cuban People (SCP), 15 CFR § 740.21, which authorizes exports and reexports of gas and other petroleum products to improve living conditions and support independent economic activity. In other words, U.S.-origin oil exports, as well as other gas and petroleum products covered by License Exception SCP, do not require separate OFAC authorizations. Exporters and reexporters are responsible for reviewing current Commerce Department guidance, see here, and ensuring that any transaction undertaken pursuant to License Exception SCP or any other license exception meet all applicable terms and conditions.
See FAQ 1226 for the definition of “Venezuelan-origin oil,” which includes petroleum products.
Date Updated: March 05, 2026
Date Released
February 25, 2026
On Thursday, OFAC issued a new version of Russia-related General License 129 (Authorizing Transactions Involving Rosneft Deutschland GmbH and RN Refining & Marketing GmbH) – this one is 129A:
Unlike a lot of these GLs which, when they get updated, they update the expiration date. This one’s different, though – 129A has no expiration date. Gemini explains why:
Since last October, there have been significant moves to transition Rosneft Deutschland GmbH (RDG) and RN Refining & Marketing GmbH (RNRM) from temporary state management to a more permanent “public-law” ownership structure.
The most critical development occurred just last month (February 2026), when the German government and European Commission cleared the way for Berlin to assume permanent control, potentially moving toward a full purchase or “amicable” acquisition to avoid the legal risks of outright expropriation.
Key Developments (October 2025 – March 2026)
1. Shift to Permanent Control (February 2026)
In late February 2026, the European Commission approved a new legal framework that allows the German government to maintain indefinite control over Rosneft’s German assets.
- Previous Model: A temporary trusteeship that required renewal every six months.
- New Model: A “public-law trust” under the German Foreign Trade Act. This establishes long-term management by the Federal Network Agency (Bundesnetzagentur) and bars Rosneft from exercising any voting rights.
- Acquisition Status: Reports indicate that independent audits have valued the assets between €3.5 billion and €4 billion (German estimate) and €6.5 billion (Rosneft estimate). Berlin is reportedly attempting to finalize a voluntary sale by Rosneft to avoid the multi-billion euro compensation claims that would follow a forced nationalization.
2. US Sanctions and “Open-Ended” Waivers (March 2026)
The ownership situation became urgent after the US imposed broader sanctions on PJSC Rosneft in late 2025, which threatened to paralyze the German refineries (PCK Schwedt, MiRo, and Bayernoil).
- General License: OFAC originally issued a temporary license in October 2025.
- Indefinite Waiver: As of March 5, 2026, OFAC issued a new, open-ended license for transactions involving Rosneft Deutschland. This removes the “sanctions cliff” that previously required renewal every few months and allows German partners and banks to continue supporting the refineries without fear of secondary sanctions.
3. Operational Continuity
Despite the legal tug-of-war, the refineries remain operational:
- PCK Schwedt: Is currently operating at approximately 80% capacity, primarily supplied via the port of Rostock and oil from Kazakhstan via the Druzhba pipeline (to bypass Russian crude).
- Current Trustee: The Federal Network Agency remains the fiduciary manager, handling all operational decisions and ensuring that no funds flow back to the Russian parent company.
Summary of Current Ownership/Control
Feature Status as of March 2026 Legal Owner PJSC Rosneft (Formal title remains, but rights are frozen). Effective Controller German Federal Network Agency (Permanent Trusteeship). Sanctions Status Exempt via open-ended US (OFAC) and UK (OFSI) licenses. Next Likely Step Settlement/Purchase agreement between Berlin and Rosneft.
Today, OFAC issued its very first General License under the Democratic Republic of the Congo (DRC) sanctions program – General License 1:
There’s a new version of General License 131:
And the related Frequently Asked Questions (FAQs) were updated, too – 1224:
1224. What negotiations does Russia-related General License 131C 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) 131C, 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 131C expires on April 1, 2026.
GL 131C 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 131C 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 131C 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: February 26, 2026
Date Released
November 19, 2025
and 1225:
1225. What activities do Russia-related General License 128B and General License 131Cauthorize 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 128B and GL 131C. 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. This GLexpires on April 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 and 131C to extend the existing authorization until April 1, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.
GL 128B and GL 131C 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 128B and GL 131C. 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 128B and GL 131C 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 128B and GL 131C 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 128B and GL 131C. Similarly, non-U.S. persons may rely upon GL 128B and GL 131C 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 128Band GL 131C, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.
Date Updated: February 26, 2026
Date Released
December 4, 2025
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On 25 February 2026, the General Licence INT/2025/8031092 was amended, the expiry date was extended to 25 August 2026.
Any persons intending to use General Licence INT/2025/8031092 should consult the copy of the Licence for full details of the permissions and usage requirements.
FAQ 174 was also amended to reflect the amendment of the general licence.
The General License:
The FAQ:
174.Can business operations with Lukoil International GmbH continue as normal with regard to UK financial sanctions?
On 15 October 2025, the UK designated PJSC Oil Company Lukoil (“Lukoil”) under the Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Regulations”). Lukoil is consequently subject to financial sanctions, as are entities owned or controlled by Lukoil.
OFSI notes the ongoing negotiations on the sale of PJSC Lukoil’s international assets.
In that context, on 27 November 2025 OFSI issued General Licence INT/2025/8031092. This GL permits the continuation of business with respect to Lukoil International GmbH (“Lukoil International”) which is a subsidiary of PJSC Lukoil and subsidiaries of Lukoil International.
Users of General Licence INT/2025/8031092 should carefully consider all relevant conditions, in particular those relating to payments made to Lukoil International and/ or Lukoil International subsidiaries.
In line with OFSI licensing practice the expiry date of General Licence INT/2025/8031092 is set out in the amended licence document. Any renewal of General Licence INT/2025/8031092 would be considered in the context of the ongoing negotiations on the sale of PJSC Lukoil’s international assets.
HM Treasury may vary, revoke or suspend General Licence INT/2025/8031092 at any time.
Amended on: 25 Feb 2026
On 23 February 2026, the General Licence INT/2024/4761108 was amended to:
- Amend the definition of “Person”.
- Include the definition of “Individual”, “Entity”, “UK Bank Account”, “Non-UK Bank Account” and “UK DP”.
- Include a new separate permission that allows an Entity to make use of the retail banking services of a designated Credit or Financial Institution to make or receive a payment of for the personal use of an individual, provided the account at the final institution in the chain of payments to which the payment is processed is a UK Bank Account or a Non-UK Bank Account.
- For the avoidance of doubt, the intended payments under this new permission remain exclusively for personal purposes and do not include payments for business or commercial activities. Possible examples of permitted payments include, but are not limited to, payments from or to entities for tuition fees, accommodation costs, pension, or living expenses.
- No payment is permitted under this General Licence if the payment relates to the provision of goods or services for commercial purposes.
- Increase the cumulative limit of permitted payments from £50,000 to £55,000.
- Extend the expiry date of the licence to 23:59 on 23 February 2028.
- The reporting requirements have been amended.
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.
The amended General Licence:
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On 24 February 2026, the General Licence INT/2026/8893924, Maritime Mutual Re-Insurance Wind Down was issued. The General Licence allows for the winding down of insurance policies written by Maritime Mutual entities and their subsidiaries before their designation.
Any persons intending to use General Licence INT/2026/8893924 should consult the copy of the Licence for full details of the definition, permissions, and usage requirements.
The General Licence:
On 24 February 2026, the General Licence INT/2026/8889196, PJSC Transneft Wind Down was issued. The General Licence allows for Persons to wind down from any transactions involving the DP to which that Person is a party.
Any persons intending to use General Licence INT/2026/8889196 should consult the copy of the Licence for full details of the definition, permissions, and usage requirements.
The General Licence:
On 24 February 2026, the General Licence INT/2025/5635700, Russian Oil Exempt Projects was amended to include any entity owned or controlled, directly or indirectly, by PJSC Transneft, following their designation by the UK. Additionally, Schedule 1 of the General Licence was amended to add the Druzhba Pipeline.
Any persons intending to use General Licence INT/2025/5635700 should consult the copy of the Licence for full details of the definition, permissions, and usage requirements
The amended General Licence:
