pc
nid 91636
Mar 30, 2026
pdonofrio@vixio.com
US Track 2
Ministry of Finance
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1738 charsUnited States Office of Foreign Assets Control Amends Russia-Related General License and Guidance
On March 30, 2026, the United States Department of the Treasury's Office of Foreign Assets Control (OFAC) issued an amended Russia-related General License 131D, titled "Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities."
The amendment permits specified transactions related to the negotiation and execution of contingent contracts for the sale of Lukoil International GmbH, alongside associated maintenance activities. This license modification reflects OFAC's ongoing management of sanctions compliance obligations for entities engaged with Russian-related assets and operations. The amendment applies to persons and entities subject to U.S. jurisdiction seeking to conduct permissible transactions within the scope of the license.
Concurrently, OFAC amended two Russia-related Frequently Asked Questions—FAQ 1224 and FAQ 1225—to provide updated guidance on sanctions compliance matters. These amendments clarify OFAC's position on permissible activities and compliance expectations for stakeholders navigating Russia-related sanctions regulations.
Interested parties should review the amended General License 131D and the updated FAQs to ensure compliance with current OFAC requirements. The amendments are effective immediately upon issuance. Additional information regarding OFAC's Russia sanctions program, including the amended license and guidance documents, is available on OFAC's official website.
REFERENCES:
Office of Foreign Assets Control. "Issuance of Amended Russia-related General License; Publication of Amended Russia-related Frequently Asked Questions." March 30, 2026. https://ofac.treasury.gov/
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1633 charsUS Office of Foreign Assets Control Issues Russia-Related General License and Publishes FAQs
On March 30, 2026, the US Office of Foreign Assets Control (OFAC) issued Russia-related General License 131D .
The general license provides that all transactions prohibited by Executive Order 14024 that are ordinarily incident and necessary to the negotiation of and entry into contracts with Lukoil or any of its affiliates for the sale, disposition or transfer of Lukoil International GmbH (LIG) or any entity in which LIG owns, directly or indirectly, individually or in the aggregate, a 50% or greater interest are authorized through May 1, 2026, provided that the performance of any such contract is made expressly contingent upon the receipt of separate authorization from OFAC.
However, the general license does not authorize:
The unblocking of any property blocked pursuant to any part of 31 CFR V .
The unblocking of any property blocked pursuant to any part of 31 CFR V .
Any transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR), including transactions involving any person blocked pursuant to the RuHSR, unless separately authorized.
Any transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR), including transactions involving any person blocked pursuant to the RuHSR, unless separately authorized.
The transfer of funds to any person or account located in Russia.
The transfer of funds to any person or account located in Russia.
Additionally, OFAC published FAQ 1224 and FAQ 1225 , which, together, provide a more detailed explanation of transactions and activities authorized under the new general license.