On May 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control issued a new general license under the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587. General License 124 authorizes the provision of petroleum services related to the Caspian Pipeline Consortium (“CPC”) and Tengizchevroil Projects, which would otherwise be prohibited by a determination, issued on January 10, 2025, that prohibits the export, reexport, sale or supply of petroleum services by U.S. persons to persons located in Russia. On January 10, 2025, OFAC issued General License 121 to temporarily authorize petroleum services related to CPC, Tengizchevroil, and Sakhalin II operations until June 28, 2025. General License 124 essentially removes the time limitation for authorizations related to the CPC and Tengizchevroil operations.
On the same day, OFAC updated Frequently Asked Question 1216 to reflect the authorizations in General License 124.