OFAC amends Russia-related GL 131D, extends Lukoil International sale talks and wind-down authorization

WASHINGTON, March 30, 2026 — The U.S. Treasury Department’s Office of Foreign Assets Control issued amended Russia-related General License 131D and updated FAQs 1224 and 1225, keeping in place a pathway for negotiations over the potential sale of Lukoil International GmbH, or LIG, and its majority-owned subsidiaries outside Russia.

The amended license authorizes transactions ordinarily incident and necessary to negotiating and entering contingent contracts with Public Joint-Stock Company Oil Company Lukoil or its affiliates for the sale, disposition or transfer of LIG entities through 12:01 a.m. EDT on May 1, 2026. Any contract must remain expressly contingent on separate OFAC authorization before a sale can be completed.

GL 131D also authorizes maintenance or wind-down of operations, contracts and other agreements of LIG entities through the same May 1 deadline, and permits blocked accounts of those entities to be used, debited or credited for those maintenance and wind-down transactions.

OFAC said the license does not authorize the unblocking of property except as specified, does not permit otherwise prohibited transactions with other blocked persons, and does not allow transfers of funds to any person or account located in the Russian Federation. The new license replaces and supersedes GL 131C in its entirety effective March 30.

In updated FAQ 1224, OFAC said it would weigh any future request to approve a sale against U.S. national security and foreign policy objectives. Treasury said a proposed transaction would need to sever LIG’s ties with Lukoil, place funds owed to Lukoil into a blocked account subject to U.S. jurisdiction until sanctions are lifted, and avoid giving Lukoil an upfront windfall, including through asset or share swaps. OFAC also said it may revoke GL 131D at any time.

Updated FAQ 1225 says GL 131D and GL 128B serve different purposes, with GL 131D aimed at enabling divestment of Lukoil assets outside Russia to non-blocked parties while continuing ordinary-course support for existing operations.