OFAC publishes GL 131E, 131F, and 131G authorizing limited Lukoil transactions

The Treasury Department's Office of Foreign Assets Control (OFAC) has published three web general licenses - GL 131E, GL 131F, and GL 131G - in the Federal Register. Each license authorizes certain transactions that would otherwise be prohibited under Executive Order 14024 and the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587.

GL 131E, issued April 29, 2026, replaces and supersedes GL 131D. It authorizes, except as limited in paragraph (d), all transactions ordinarily incident and necessary to negotiate and enter into contingent contracts for the sale, disposition, or transfer of Lukoil International GmbH ("LIG") or any entity in which LIG owns a 50 percent or greater interest. The authorization is effective through 12:01 a.m. Eastern Daylight Time, May 30, 2026, and permits use of blocked LIG accounts for maintenance or wind-down activities.

GL 131F, issued May 28, 2026, supersedes GL 131E and extends the same authorizations through 12:01 a.m. Eastern Daylight Time, June 27, 2026. The license retains the definition of "contingent contracts" and the same exclusions listed in paragraph (d).

GL 131G, issued June 25, 2026, supersedes GL 131F and further extends the authorization window to 12:01 a.m. Eastern Daylight Time, July 25, 2026, with identical terms and limitations.

All three licenses expressly do not authorize the unblocking of any property, any transactions involving other persons blocked under the Russian Harmful Foreign Activities Sanctions Regulations, or the transfer of funds to any person or account located in the Russian Federation. The full texts are available on OFAC's website.