OFAC extends Lukoil International divestment talks license and updates guidance

WASHINGTON, April 29, 2026 — The U.S. Treasury Department’s Office of Foreign Assets Control issued Russia-related General License 131E, extending through 12:01 a.m. EDT on May 30, 2026, authorization for transactions ordinarily incident and necessary to negotiate and enter contingent contracts with Lukoil or its affiliates for the sale, disposition or transfer of Lukoil International GmbH, or LIG, and its majority-owned subsidiaries. OFAC said the action also authorizes maintenance or wind-down activities for those entities through the same date.

The agency said any contract signed under GL 131E must be expressly contingent on separate OFAC authorization before a sale can actually be completed. The license does not authorize the unblocking of property beyond specified use of blocked accounts for permitted maintenance activity, does not permit otherwise prohibited Russia sanctions dealings with blocked persons outside the license scope, and bars transfers of funds to any person or account in the Russian Federation. GL 131E replaces and supersedes GL 131D effective April 29.

OFAC also updated FAQs 1224 and 1225 to clarify that GL 131E is meant to support divestment of Lukoil assets outside Russia to non-blocked parties. The guidance says authorized negotiations include work on definitive agreement terms and financial, legal and operational due diligence. However, OFAC said any later request to complete a sale would be evaluated against U.S. national security and foreign policy objectives, including whether the deal fully severs LIG from Lukoil, blocks funds owed to Lukoil under U.S. jurisdiction until sanctions are lifted, and avoids providing Lukoil with an upfront windfall.

FAQ 1225 adds that GL 131E and separate GL 128C serve different purposes, with 131E covering all LIG entities for maintenance, wind-down and contingent sale negotiations, while 128C remains focused on a narrower group of Lukoil retail service station operations outside Russia. OFAC said non-U.S. persons generally do not risk sanctions exposure for activity that is generally authorized for U.S. persons under those licenses, so long as the activity stays within license terms, including the prohibition on transferring funds into Russia.