Mr. Sanctions

Category: Frequently Asked Questions (FAQs)

  • May 4, 2026: Another OFAC Day, Another version of an OFAC GL (and the related FAQ)

    This time it’s Venezuela-related General License 5W (Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After June 19, 2026):

    venezuela_gl5wDownload

    And Frequently Asked Question 595 got an update, too:

    595. What does Venezuela-related General License 5W 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    General License 5 was replaced and superseded by General License 5A on October 24, 2019 with a delay in the effectiveness of the authorization in the general license.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 5W on May 4, 2026, which further delays the effectiveness of the authorization in GL 5 until June 19, 2026. Between October 24, 2019 and June 19, 2026 (the date the authorization in General License 5Wbecomes 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: May 04, 2026

    Date Released

    January 20, 2022

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  • May 1, 2026: OFAC Iran-related Updates, Part 2: General Licenses, FAQs and another Alert… oh, my!

    First, Iran General License W (Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on May 1, 2026):

    iran_glwDownload

    and the new Frequently-Asked Question 1250:

    IRAN SANCTIONS

    1250. Are Iranian digital asset exchanges blocked under OFAC sanctions?

    Answer

    Yes. Executive Order (E.O.) 13599, as implemented by section 560.211(b) of the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR), blocks the property and interests in property of Iranian financial institutions. An Iranian financial institution is blocked pursuant to E.O. 13599 regardless of whether it is listed on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List). Iranian digital asset exchanges meet the regulatory definition of an “Iranian financial institution” as persons that engage in the business of activities described in section 560.324 of the ITSR.

    All property and interests in property of Iranian digital asset exchanges in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked pursuant to section 560.211 of the ITSR and must be reported to OFAC. See FAQ 160 for additional information regarding the sanctions implications of E.O. 13599. For additional information regarding the application of sanctions to digital assets, please see FAQs 559, 560, 561, 562, 563, 594, 646, and 647, as well as OFAC’s Sanctions Compliance Guidance for the Virtual Currency Industry.

    Date Released

    May 1, 2026

    and a new OFAC Alert (Hormuz News U Can Uz, as Stephen Colbert would say):

    20260501_hormuz_tolls_alertDownload

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  • April 29, 2026: I’m on E… OFAC Russia-related General License 131E, that is

    Here it is – “Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities”:

    russia_gl131eDownload

    And two amended FAQs:

    Russian Harmful Foreign Activities Sanctions

    1225. What activities do Russia-related General License 128C and General License 131E authorize related to Lukoil International GmbH (LIG)? 

    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 131E. 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, and 131E to extend the existing authorization until May 30, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

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

    Date Updated: April 29, 2026

    Updated on Apr 29, 2026

    Russian Harmful Foreign Activities Sanctions

    1224. What negotiations does Russia-related General License 131E authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets? 

    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) 131E, 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 131E expires on May 30, 2026.

    GL 131E 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 131E 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 131E 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: April 29, 2026

    Updated on Apr 29, 2026

    And my apologies for the Blondie deep cut (from Plastic Letters, when I first started listening to them)…

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  • April 28, 2026: OFAC Update, Part 2: New Iran FAQ, and Iran Alert

    On Tuesday, OFAC issued Iran FAQ 1249:

    1249. Are “toll” payments to Iran for safe passage through the Strait of Hormuz authorized?

    Answer

    No. Payments to the Government of Iran or the Islamic Revolutionary Guard Corps (IRGC), directly or indirectly, for safe passage through the Strait of Hormuz would not be authorized for U.S. persons, including U.S. financial institutions, or for U.S.-owned or -controlled foreign entities.

    Such payments also create significant sanctions exposure for non-U.S. persons. Specifically, foreign financial institutions and other non-U.S. persons risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. This includes the Government of Iran and the IRGC, which is sanctioned pursuant to several authorities, including nonproliferation and counterterrorism sanctions authorities, and is designated as a Foreign Terrorist Organization.

    Foreign persons that are engaged in certain transactions could also risk sanctions exposure under authorities such as Executive Order 13902, which authorizes sanctions on, among others, persons who have knowingly engaged in certain significant transactions involving determined sectors of the Iranian economy or who have been determined to operate in those sectors, including the financial and petroleum and petrochemical sectors.

    Date Released

    April 28, 2026

    and a new OFAC Alert about teapot oil refineries:

    20260428_teapot_refinery_alertDownload

    and Treasury had an accompanying press release.

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  • April 24, 2026: OFSI issues new GL and makes some FAQ changes

    Office of Financial Sanctions Implementation HM Treasury

    General Licence INT/2026/9512597 issued and 1 FAQ added, 1 FAQ withdrawn and 2 FAQs amended

    On 24 April 2026, the General Licence INT/2026/9512597 was issued. The General Licence pertains to legal Services which will take effect following the expiry of Legal Services General Licence INT/2025/7323088 on 28 April 2026.

    Any persons intending to use General Licence INT/2026/9512597 should consult the copy of the Licence for full details of the definition, permissions, and usage requirements.

    FAQ 170 was withdrawn and FAQ 184 was added following the new General Licence. FAQ 50 and FAQ 57 were amended.

    Don’t want to click? Here’s the new General License’s Publication Notice:

    INT.2026.9512597_PNDownload

    and the General Licence:

    INT.2026.9512597_GLDownload

    the new FAQ:

    Legal Services General Licence (INT/2026/9512597) 

    184. The Legal Services General Licence has been updated and is available online. What has changed and what does this mean for law firms, legal advisors, Counsel and providers of Expenses?

    General Licence INT/2026/9512597 refreshes the fees and expenses caps for Parts A and B for the six-month period from 29 April 2026 until 28 October 2026, when the licence expires.

    In addition to refreshing the caps, OFSI has also made some amendments to the General Licence.

    General Licence INT/2026/9512597 introduces a new definition:

    ‘DP Group’ means a DP designated for the purposes of an asset freeze by the UK under the UK Autonomous Sanctions Regulations, excluding those designated for the purpose of compliance with United Nations obligations, together with any entities owned or controlled by that DP.

    Several permissions and conditions of the General Licence have been amended to incorporate this definition. Please consult the full licence online.

    A DP and its owned or controlled entities may pay the legal fees for that DP or another entity within that DP group.

    The Licence fee and expenses caps apply to all matters that a Law Firm (or Counsel, if engaged under a direct instruction) are handling for individuals or entities within a DP group, or, where there is no DP Group, for the designated entity or individual.

    General Licence INT/2026/9512597 has also been amended to permit payments to a Non-UK Bank Account held by an individual regulated by the Solicitors Regulation Authority, the Law Society of Scotland or the Law Society of Northern Ireland, who provides Legal Services outside the United Kingdom, otherwise than at a branch of a Law Firm that falls within paragraph 8.2.1 (Part A) or 11.2.1 (Part B). Please consult the full licence for the complete permission.

    Added on: 24 April 2026

    and the amended ones:

    Legal Services General Licence (INT/2024/5334756)

    50. How do the fees and expenses caps apply? Is it per DP (i.e., for all a DP’s matters across all law firms) or is it per law firm being instructed by a DP? 

    OFSI has amended the General Licence so the £2,000,000 caps for each of Parts A and B, and the related expenses caps, now apply to each law firm instructed by the DP Group, or where there is no DP Group, to the designated entity or individual.  

    The caps cover all the matters being handled by that law firm for the DP Group, or where there is no DP Group, to the designated entity or individual. This means that the caps do not apply to each individual matter handled by that law firm.

    Amended on: 24 April 2026

    Scope of Legal Services General Licence 

    57. Can an entity owned and/or controlled by a designated person (DP) pay the DP’s legal fees even though the entity did not explicitly receive the legal advice? 

    Yes, provided the conditions of the General Licence are met. The General Licence states at paragraph 5 that a DP may pay professional legal fees, Counsel’s fees, and/or Expenses to a Law Firm, a Legal Adviser, Counsel or a provider of Expenses for Legal Services which have been provided to that DP or to any other DP in the same DP Group.”

    The General Licence defines a DP as “those individuals or entities designated (or owned or controlled by an individual or entity designated) … excluding those designated for the purpose of compliance with United Nations obligations.”

    Please see related FAQ 50.   

    Amended on: 24 April 2026

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  • April 16, 2026: OFAC Update 2, Part 2: Venezuela General Licenses & Frequently Asked Question

    From OFAC’s Recent Actions Notice:

    The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Venezuela General License 56, “Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government of Venezuela,”:

    venezuela_gl56Download

    and Venezuela General License 57, “Authorizing Financial Services Transactions Involving Certain Venezuelan Banks and Government of Venezuela Individuals.”

    venezuela_gl57Download

    OFAC is also issuing one Venezuela-related Frequently Asked Question, FAQ 1248.

    1248. Since January 2026, OFAC has issued a series of Venezuela-related General Licenses related to purchases and investment in Venezuela’s natural resource sectors, such as Venezuela-related General Licenses (GLs) 48A and 50A, that include a reporting requirement. Which parties are responsible for providing such reports pursuant to those General Licenses?

    Answer

    In general, the parties engaged in the primary authorized activity are responsible for complying with the applicable reporting requirements in these Venezuela-related GLs. Parties that are only indirectly involved or providing services ancillary to the primary authorized activity are not required to file reports pursuant to the applicable license. For example, a company providing services for the generation of electricity in Venezuela under GL 48A would need to report such activities pursuant to that license, but a bank processing payments related to those services does not also need to provide a report. Similarly, under GL 50A, the parties listed in the annex would be required to provide reports describing their activities undertaken pursuant to the license, whereas the bank processing those related payments would not.

    Date Released

    April 14, 2026

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  • April 14, 2026: OFAC Update 1, Part 2: New and updated General Licenses, and an updated Frequently Asked Question

    From OFAC’s Recent Actions Notice:

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Counter Terrorism General License 35, “Authorizing the Wind Down of Transactions Involving Entities Blocked on April 14, 2026.”

    ct_gl35Download

    OFAC is also issuing Russia-related General License 128C, “Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia,” 

    russia_gl128cDownload

    Russia-related General License 130A, “Authorizing Transactions Involving Certain Lukoil Entities in Bulgaria,

    russia_gl130aDownload

    and is amending one Russia-related Frequently Asked Question (FAQ 1225).

    1225. What activities do Russia-related General License 128C and General License 131D 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 131D. 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 GL 131B, GL 131C, and GL 131D to extend the existing authorization until May 1, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

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

    Date Updated: April 14, 2026

    Date Released

    December 4, 2025

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  • April 8, 2026: OFAC updates Russian General License 13 & associated Frequently Asked Questions

    Today, OFAC issued Russia-related General License 13Q:

    russia_gl13qDownload

    and updated two FAQs:

    1118. As of December 2022, the Government of the Russian Federation may require a so-called “exit tax” payment prior to the divestment of assets located in the Russian Federation, potentially requiring transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation. Do U.S. sanctions prohibit the payment of this so-called “exit tax”? Does Russia-related General License (GL) 13Q authorize transactions that involve the payment of this exit tax? 

    Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive), prohibits the following activities by U.S. persons: any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities (collectively, “Directive 4 entities”). As noted in FAQ 1002, this includes both direct and indirect transactions.

    OFAC issued the Russia-related Sovereign Transactions Directive with the explicit aim of preventing the Government of the Russian Federation from leveraging these institutions and their holdings of international reserves in ways that would undermine the impact of U.S. sanctions. Information currently available to OFAC suggests so-called “exit taxes” imposed by the Government of the Russian Federation involve payments to Directive 4 entities. Consequently, U.S. persons whose divestment from the Russian Federation will involve the payment of such an exit tax require a specific license from OFAC prior to the payment of such tax, unless otherwise authorized by OFAC.

    GL 13Q authorizes U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications involving Directive 4 entities that would otherwise be 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. Payment of exit taxes is not considered ordinarily incident and necessary to day-to-day operations in the Russian Federation and, thus, is not authorized under GL 13Q.

    Therefore, U.S. persons whose divestment of assets in the Russian Federation will involve a payment of such an “exit tax” should seek a specific license from OFAC. Such persons may submit a request for a specific license with OFAC’s Licensing Division online at https://ofac.treasury.gov/ofac-license-application-page. License applications related to these payments should include information regarding the amount of the exit tax, the amount of ongoing taxes that would otherwise be paid to the Government of the Russian Federation should divestment not occur, the impact of a failure to pay the tax on the employees of the exiting company, the specific economic activity in Russia of the exiting company, and the impact on the Russian Federation of the divestment. OFAC will expedite its review of such requests, which will be evaluated on a case-by-case basis.

    While OFAC is aware that the Commission established by the Russian Federation to review such divestments may include individuals from entities subject to the Russia-related Sovereign Transactions Directive or individuals listed on the Specially Designated Nationals and Blocked Persons List, U.S. persons do not need to seek authorization from OFAC for their Russian buyers to submit an application to the Commission regarding a divestment transaction.

    Date Updated: April 08, 2026

    Updated on Apr 08, 2026

    Russian Harmful Foreign Activities Sanctions

    999. What authorizations exist for entities subject to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive)? 

    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 Russia-related General License (GL) 115C to authorize civil nuclear energy-related transactions, 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 115C, and GL 132 continue to authorize against the Russia-related Sovereign Transactions Directive.

    Date Updated: April 08, 2026

    Updated on Apr 08, 2026

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  • April 8, 2026: ¿Habla usted OFAC?

    From today’s OFAC Recent Actions page:

    OFAC has published Spanish translations of Venezuela General License 46B, “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products;” Venezuela General License 47, “Authorizing the Sale of U.S.-Origin Diluents to Venezuela;” Venezuela General License 48A, “Authorizing the Supply of Certain Items and Services to Venezuela;” Venezuela General License 49A, “Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela;” and Venezuela General License 50A, “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities.” The translations of these General Licenses are available at this link, and the translations of 19 associated Frequently Asked Questions are available at this link. Note: These Spanish translations are for informational purposes only.

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  • April 1, 2026: OFAC issues more aggressive guidance, a General License and FAQs about the Shadow Fleet

    U.S. DEPARTMENT OF THE TREASURY

    Office of Foreign Assets Control

    April 1, 2026

    Publication of Sanctions Advisory: Guidance on Identifying “Non-Standard Maritime Silhouettes” and Active Camouflage within the Shadow Fleet

    The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), in coordination with the U.S. Department of State and the U.S. Coast Guard, is issuing this advisory to alert the maritime industry to “Visual Signal Obfuscation” (VSO) tactics currently employed by the Shadow Fleet to circumvent the G7+ Price Cap and avoid detection in high-traffic corridors.

    As outlined in Executive Order 14501, “Addressing Extra-Territorial Maritime Deception,” U.S. persons are advised that the use of “Trompe-l’œil” hull painting, inflatable superstructure extensions, and “active-chameleon” heat-shielding technology constitutes a significant evasion risk.

    Regulatory Concerns: The “Iceberg” and “Megayacht” Protocols

    OFAC has identified a trend where sanctioned crude oil tankers are undergoing structural modifications to appear as non-sanctioned vessel types when viewed from satellite or aerial surveillance. Recent findings include:

    • Pseudo-Leisure Conversions: Tankers utilizing magnetic “hull-wraps” to mimic the visual signature of luxury pleasure craft or research vessels.
    • Active Camouflage (AC): The application of light-refractive coatings that cause the vessel to blend into sea-state patterns or, in Arctic routes, mimic the geometric profile of large icebergs.
    • Bio-Mimicry Signatures: The deployment of acoustic decoys that broadcast the frequency of migratory whale pods to confuse sonar-based tracking systems.

    Compliance Expectations

    Marine insurers, port authorities, and bunkering services are expected to conduct “Optical Due Diligence.” If a vessel’s length-to-beam ratio appears to “shimmer” or fluctuate during daylight hours, it must be flagged as a “Potential Visual Evasion Event” (PVEE).

    And a new General License:

    GL 1-APRDownload

    And a new Frequently Asked Question:

    Frequently Asked Question (FAQ) 1401

    Q: My satellite imagery shows a tanker that looks like a giant floating rubber duck. Is this a sanctioned vessel?

    A: Possibly. Under the “Strict Liability” standard, the internal cargo (crude oil) determines the sanctions status, regardless of whether the external hull is yellow, buoyant, or has a beak. OFAC recommends that you do not “squeeze” the duck until you have verified the Ultimate Beneficial Owner (UBO) via the hotline at 1-800-APR-FOOL.

    oh, and one more thing, in case it wasn’t clear…

    Thanks a bunch, Gemini! April Fool!

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