Mr. Sanctions

Category: Frequently Asked Questions (FAQs)

  • OFAC Amends two Russia-related FAQs

    As per the OFAC Notice:

    Issuance of Amended Russia-related Frequently Asked Questions

    Release Date

    12/18/2025

    Recent Actions Body

    OFAC is issuing two amended Russia-related Frequently Asked Questions, FAQ 1224 and 1225.

    The FAQs:

    1224. What negotiations does Russia-related General License 131A 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 PJSC 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) 131A, 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 131A expires on January 17, 2026.

    GL 131A 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 131A 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 131A 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: December 18, 2025

    Date Released

    November 19, 2025

    and:

    1225. What activities do Russia-related General License 128B and General License 131A 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 128B and GL 131A.  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 GL expires 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.  This GL has a shorter duration as it expires on January 17, 2026.  Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.  

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

    Date Updated: December 18, 2025
     

    Date Released

    December 4, 2025

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  • December 17, 2025: OFAC Updates Two Russia-related General Licenses, and related FAQs

    From the OFAC Notice yesterday:

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 55E, “Authorizing Certain Services Related to Sakhalin-2;” and Russia-related General License 115C, “Authorizing Certain Transactions Related to Civil Nuclear Energy.”

    Additionally, OFAC is amending eight Russia-related Frequently Asked Questions: FAQs 967, 978, 999, 1011, 1117, 1182, 1203, and 1216.

    Here are the two updated GLs:

    russia_gl55eDownload

    and:

    russia_gl115cDownload

    Here’s a link to a page with all the updated FAQs (in reverse numerical order, for some reason).

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  • December 17, 2025: OFSI updates two General Licences and adds a FAQ

    OFSI General Licences INT/2025/7628424 and INT/2025/7323088 amended. FAQ 175 added.

    On 17 December 2025, OFSI General Licences INT/2025/7628424 and INT/2025/7323088were amended.

    There has been an update to the definition of “IT Providers” and an amendment to the permissions in General Licence INT/2025/7628424.

    The definition of “Legal Services” has been updated in General Licence INT/2025/7323088. See FAQ 175 for details of this amendment.

    Any persons intending to use General Licence INT/2025/7628424 and General Licence INT/2025/7323088 should consult the copy of the Licence for full details of the permissions and usage requirements.

    General Licence INT/2025/7628424:

    INT-2025-7628424Download

    General Licence INT/2025/7323088:

    20251211_INT.2025.7323088_GLDownload

    FAQ 175:

    Yes. On 17 December 2025, the Legal Services General Licence INT/2025/7323088 was amended to clarify that legal advice and/or representation in dispute resolution is included in the definition of “Legal Services”.

    This was first clarified in a version of the Legal Services General Licence issued 28 March 2025 (INT/2024/5334756). It was not captured in the subsequent issue of the expired General Licence: INT/2025/6160920 dated 28 April 2025, and although not included in the original version of the current Legal Services General Licence INT/2025/7323088 (due to expire 28 April 2026), this has now been amended.

    Added on: 17 Dec 2025

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  • December 16, 2025: Canada adds a ship-ton of new guidance

    The Sanctions Bureau at Global Affairs Canada has released guidance related to the listing of ships under Canada’s sanctions regime.

    From their Frequently Asked Questions:

    Q: What are “Listed”, “Named” or “Designated” Ships?

    A: Some sanctions regulations prohibit certain activities in relation to certain ships, identified by their International Maritime Organization (IMO) number. In such cases, the relevant sanctions regulation will refer to “listed”, “named”, or “designated” ships. These terms are often used interchangeably when discussing sanctions, although regulations are specific in their usage of these terms.

    Q: What happens when a ship is designated?

    A: When a ship’s International Maritime Organization (IMO) number is listed under Regulations pursuant to the Special Economic Measures Act, the ship is subject to a ban on docking in Canada or passing through Canada.

    From the Listed persons, mistaken identity and delisting page:

    Listed persons or ships under the United Nations Act

    When the United Nations Security Council (UNSC) decides to impose sanctions in response to a threat to international peace and security, it is practice that a Security Council Committee is created to oversee implementation of the sanctions. Each committee publishes the names of individuals, entities or ships affected by the corresponding sanctions. They also publish the specific measures that apply to each listed name. With the exception of the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism (RIUNRST), regulations made under Canada’s United Nations Act refer to the names of listed persons (both individuals and entities) and ships published by the relevant Security Council Committee. The names of persons listed under RIUNRST are published in the Schedule to the regulations.

    See the United Nations Security Council Consolidated List available on the United Nations web site for all individuals, entities and ships subject to measures imposed by the Security Council.

    The Forms for delisting applications, requests for particulars and certificate of mistaken identity page has been updated to say:

    An individual or entity designated pursuant to either the Special Economic Measures Act (SEMA) or the Justice for Victims of Corrupt Foreign Officials Act (JVCFOA) may apply to the Minister of Foreign Affairs to have their name removed from the sanctions list. Any person that owns, operates or manages a ship listed under the SEMA may also apply to the Minister  of Foreign Affairs to have the International Maritime Organization (IMO) number of the ship removed from the sanctions list.

    To apply for the delisting of your name as a designated individual or entity, or for the delisting of a ship’s IMO number from the Consolidated Canadian Autonomous Sanctions List, complete the form below. Once submitted, Global Affairs Canada will assess the information and contact you directly if additional information is required. Processing times for any delisting application only starts the day the Sanctions Bureau receives all required documentation to complete the application, and no further information or clarification is required. Note that required information may vary based on the specific circumstances that apply. The department will contact you if additional information is required.

    Designated individuals or entities, or their representatives (such as a legal representative, private individual, corporate representative, NGO or another representative), can also request information pertaining to their designation. These requests for particulars can also be submitted using the forms below.

    Those who own, operate or manage a ship listed in regulations made under Special Economic Measures Act, or their representatives, can request information pertaining to the ship’s designation using the online form below.

    Note: Any details, including personal information, provided in an application for delisting, a request for particular or certificate of mistaken identity, may be sent to the RCMP and other agencies or departments of the Government of Canada. These details are used to verify the identity of applicants and designated individuals, entities or ships, and to assess whether a designated individual, entity or ship meets the criteria to have their name removed from the sanctions list, as well as for the administration and enforcement of the sanctions regime.

    and two forms were added:

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  • Daily Digest for Thursday, December 4, 2025

    Daily Digests are simple lists of hyperlinks to new content released by sanctions and export control regulators. When appropriate, additional posts of analysis and commentary, as well as summarizations and rephrasing of the contents will be posted separately.

    Mr. Sanctions does not attempt to comprehensively cover the worlds of sanctions and export control. Opinions expressed here are my own and do not represent that of my past current or future employers.

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