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.
New FAQs added – Transneft ports, payments and insurance
OFSI has published new FAQs (188-195) clarifying how UK financial sanctions apply in relation to Transneft and associated activity. These FAQs provide additional guidance to industry on how relevant prohibitions operate in practice, including when a licence may be required and how firms should approach compliance risks.
The FAQs respond to stakeholder queries and aims to support a consistent understanding of the regime, helping to reduce the risk of circumvention. We encourage insurers, financial institutions and maritime operators to review the guidance and ensure internal processes reflect these considerations.
Here they are:
PJSC Transneft
188. Does insuring a vessel calling at a PJSC Transneft owned or controlled port automatically engage UK sanctions?
No.
UK insurers providing insurance or reinsurance cover for vessels simply calling at PJSC Transneft-owned or controlled ports, in itself, is unlikely to engage UK financial sanctions.
The fact that a UK insured vessel calls at a PJSC Transneft owned or controlled port does not, in itself, automatically engage UK financial sanctions. Although UK financial sanctions do not determine whether a vessel may call at a particular port, UK financial sanctions, however, may still apply to any financial activities connected with such voyages.
Questions relating to port access, shipping routes, or trade restrictions fall outside the scope of UK financial sanctions and are governed by other regulatory frameworks.
For guidance on assessing insurance claims, see FAQs 189-190.
Added on: 11 Jun 2026
189. What are some of the key considerations when assessing insurance claims and payouts relating to PJSC Transneft owned or controlled ports?
Depending on the specific facts of the case, the key considerations are whether a payment under an insurance policy would engage the asset freeze prohibitions, for example regulations 12 and 13 of the Russia Regulations- making funds available to, or for the benefit of, designated persons, including PJSC Transneft.
If so, a licence from OFSI would be required before any such payment can be made.
Added on: 11 Jun 2026
190. Can UK insurers pay claims that do not involve PJSC Transneft or PJSC Transneft owned or controlled ports?
Whether or not such claims can be paid without an OFSI licence will depend on the circumstances and facts of the case.
For example, although a payment may not result in a direct payment to a PJSC Transneft owned or controlled port/entity, firms must assess whether other UK asset freeze prohibitions are engaged, for example regulation 13 of the Russia Regulations- making funds available for the benefit of a designated entity, including PJSC Transneft.
Firms must make their own assessment on whether any indirect benefit arises to a designated person or whether any of the other asset freeze prohibitions are engaged.
Added on: 11 Jun 2026
191. Does compliance with EU or other sanctions regimes ensure compliance with UK sanctions?
No.
Compliance with EU or other sanctions regimes as it relates to PJSC Transneft should not be taken as evidence of compliance with UK financial sanctions. The UK maintains an independent sanctions framework, and firms must ensure full adherence to UK specific requirements.
Added on: 11 Jun 2026
192. Do payments made in connection with calling at a PJSC Transneft-owned or controlled port engage UK financial sanctions?
Potentially.
Primarily, there will have to be a UK nexus in relation to the payment(s). Once this has been established, payments such as port fees and terminal charges, amongst others, may engage UK financial sanctions if for example funds are made available to, or for the benefit of, designated persons, including PJSC Transneft (regulations 12 and 13 of the Russia Regulations).
In such cases, the asset freeze prohibitions are likely to apply, and a licence from OFSI may be required. It is for firms (including UK shipowners, charterers or ship managers for example) to assess whether UK financial sanctions are engaged in relation to such payments.
Added on: 11 Jun 2026
193. Can UK financial institutions support transactions linked to voyages involving PJSC Transneft infrastructure?
UK financial institutions (such as banks or other financial firms) must assess transactions on a case-by-case basis.
Where a transaction would result in funds or economic resources being made available to, or for the benefit of PJSC Transneft, the asset freeze prohibitions are likely to apply (Regulations 12 and 13 of the Russia Regulations).
Financial institutions should ensure they conduct appropriate due diligence and consider whether an OFSI licence is required before processing any such transaction.
Added on: 11 Jun 2026
194. Does the involvement of PJSC Transneft infrastructure (e.g. oil pipelines or storage facilities) automatically engage UK financial sanctions (where a UK nexus exists)?
No.
The mere involvement of PJSC Transneft infrastructure in a supply chain does not, by itself, automatically engage UK financial sanctions. However, firms must conduct their own assessment and apply for an OFSI licence should one be required, for example, where involvement of PJSC Transneft infrastructure will result in funds being made available to PJSC Transneft (Regulation 12 of the Russia Regulations).
Added on: 11 Jun 2026
195. Do UK financial sanctions apply to goods (e.g. oil) transported via Transneft infrastructure (e.g. pipelines)?
Not automatically.
UK financial sanctions are unlikely to be engaged solely because goods have been transported via infrastructure owned or controlled by a designated person (such as PJSC Transneft).
However, the asset freeze prohibitions for example may be engaged where activities involving those goods (including payments for transport, storage or port services) result in funds being made available to, or for the benefit of, designated persons, including PJSC Transneft (regulations 12 and 13 of the Russia Regulations). Firms must conduct their own assessment on whether UK financial sanctions are engaged and apply for an OFSI licence should one be required.
Added on: 11 Jun 2026
Mr. Sanctions’ editorial note: It would be really, really nice if OFSI’s links went directly to the thing they reference. In this case, the link takes you to the start of the Russia FAQ section, even though there is a special heading for these Transneft FAQs. And when there is a sanctions update, that link takes you to a page where you then have to click again to get to the actual PDF. Yeah, it’s a comparatively small thing, but a blogger can dream, can’t he?
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.
Today, OFSI has published FAQ 187 on how mandatory corporate actions (MCAs) engage the Russia and Belarus Regulations, providing clarity for those trading transferable securities and money market instruments.
The FAQ explains that new instruments, created through an MCA will not automatically engage Regulation 16 of the Russia Regulations or Regulation 15A of the Belarus Regulations. Whether these provisions apply will depend on the specific facts, and the FAQ includes a worked example illustrating how this assessment may be made.
This guidance supports firms to continue trading whilst remaining compliant with UK sanctions.
Frequently Asked Question 187:
187. For the purposes of regulation 16 of the Russia Regulations and regulation 15A of the Belarus Regulations, how should the “date of issue” of a transferable security or money market instrument be determined, including where instruments or securities issued pursuant to a mandatory corporate action (MCA) relate to securities or instruments issued prior to the dates referred to in regulations 16 and 15A?
These regulations prohibit dealing with transferrable securities and money market instruments issued by certain persons on or after certain specified dates. Dealing with transferrable securities and money market instruments that were issued before the specified dates is not prohibited, provided the activity does not otherwise breach the Russia Regulations or the Belarus Regulations (e.g. by making funds available to a designated person).
In some cases, a new transferable security or money market instrument is created in respect of an instrument or security issued prior to the specified dates referred to above (including in the context of an MCA) which could then potentially be caught by the relevant regulations. Determining whether this is the case is fact-dependent and will be considered by OFSI on a case-by-case basis (but determinations will only be made if relevant to specific OFSI casework). In that consideration, OFSI will place significant weight on whether an issuance (including as part of an MCA) results in finance being raised for the issuer.
For example, regulation 16 or regulation 15A may not apply if:
Shares subject to regulation 16 (or regulation 15A) originally issued prior to the relevant date in regulation 16 (or regulation 15A) become subject to a mandatory stock split after that date;
that stock split does not raise new finance for the company undertaking it; and;
there is no material change to the rights and/or value of the shares.
As of June 4, 2026, GAESA, MININT, and MINFAR are all blocked pursuant to Executive Order (E.O.) 14404. These three entities are also blocked pursuant to the Cuban Assets Control Regulations (CACR), and MININT is also blocked pursuant to the Global Magnitsky sanctions program under E.O. 13818, as of January 2021. Non-U.S. persons, including foreign financial institutions, are exposed to sanctions risk for engaging in transactions with persons designated under E.O. 14404. Sanctions risk also extends to transactions with any entity in which GAESA, MININT, or MINFAR own, directly or indirectly, a 50 percent or greater interest. Many of the entities listed on the CRLare 50 percent or more owned by one of these three entities and therefore present the same sanctions risk. In addition, any non-blocked CRL entity may become the subject of future sanctions actions. Consequently, persons transacting with any entity on the CRL may run the risk of themselves being sanctioned by the U.S. government.
Non-U.S. persons should consider conducting enhanced due diligence to inform a risk-based approach to transactions with GAESA, MININT, MINFAR, or any entity in which they own, directly or indirectly, a 50 percent or greater interest. As part of such due diligence, non-U.S. persons are encouraged to consult all available sources to inform their independent assessment regarding the network of entities under GAESA, MININT, and MINFAR, including trusted sources provided by the U.S. government, such as the CRL.
Yes. OFAC’s June 2, 2026 designation of Iran-based digital asset exchanges Nobitex, Wallex, Bitpin, and Ramzinex pursuant to Executive Order (E.O.) 13902 for operating in the Iranian financial sector means that foreign financial institutions and other non-U.S. persons who engage in certain transactions with these exchanges also risk exposure to sanctions under E.O. 13902. For example, pursuant to E.O. 13902, OFAC has authority to:
Designate persons that have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Nobitex, Wallex, Bitpin, and Ramzinex; or
Prohibit or impose strict conditions on correspondent account or payable-through account opening or maintenance by foreign financial institutions that have knowingly conducted or facilitated any significant financial transaction for or on behalf of Nobitex, Wallex, Bitpin, and Ramzinex.
In addition, foreign financial institutions may be exposed to mandatory statutory sanctions for engaging in significant financial transactions with Nobitex, Wallex, Bitpin, and Ramzinex, designated Iranian financial institutions, pursuant to the National Defense Authorization Act of Fiscal Year 2012. Please see FAQ 174 for more information.
1249. Are “toll” payments to Iran for safe passage through the Strait of Hormuz authorized? Is receiving guarantees or services from Iran for or related to safe passage authorized, even when no payment is made?
Answer
No. Payments to and guarantees from 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. Regardless of whether a payment is made, U.S. persons are prohibited from receiving services from the Government of Iran, including services related to a guarantee of safe passage. For additional guidance, please see “OFAC Alert: Sanctions Risks of Iranian Demands for Strait of Hormuz Passage.”
Iran created a new entity, the so-called Persian Gulf Strait Authority (PGSA), to collect tolls and extort vessels transiting the Strait of Hormuz. On May 27, OFAC designated PGSA pursuant to our counterterrorism authorities, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the IRGC. Cooperating with or engaging in direct or indirect transactions or dealings, including the receipt of services from the PGSA, carries sanctions risk.
Payments or services for or related to safe passage 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 designated as a Foreign Terrorist Organization and sanctioned pursuant to several authorities, including nonproliferation and counterterrorism sanctions authorities.
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.
1 FAQ added: Russia (Sanctions) FAQ on Huobi Global S.A.
OFSI has published a new Frequently Asked Question (FAQ) on the application of UK financial sanctions to the HTX cryptocurrency exchange.
The FAQ explains that, following the UK’s designation of Huobi Global S.A. on 26 May 2026, OFSI considers that the HTX cryptocurrency exchange is subject to UK financial sanctions.
186. Does the designation of Huobi Global S.A. apply to the HTX cryptocurrency exchange?
Yes. On 26 May 2026, the UK designated HUOBI GLOBAL S.A. (“Huobi”) under the Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Regulations”). Huobi is consequently subject to financial sanctions, as are entities owned or controlled by Huobi.
OFSI considers that the HTX cryptocurrency exchange is subject to the UK’s financial sanctions due to its ownership by Huobi, meeting the condition in regulation 7(2)(a) of the Russia Regulations.
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.
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):
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.
