On October 29, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control issued a new general license (“GL”) under the Russian Harmful Foreign Activities Sanctions Regulations (“RuHSR”), 31 CFR part 587. GL 129 was issued to temporarily authorize transactions with Rosneft Deutschland GmbH (RN Germany) or RN Refining & Marketing GmbH, or any entity in which these companies owns a 50 percent or greater interest. These transactions are only authorized until April 29, 2026.
On the same day, OFAC amended Frequently Asked Question 1216 to explain recent actions taken by the U.S. Department of the Treasury with regards to the provision of petroleum services to Russia. FAQ 1216 provides an overview of the Petroleum Services Determination that took effect on February 27, 2025, which was issued pursuant to Executive Order 14071 to prohibit petroleum services to Russia. FAQ 1216 also discusses an exception to the prohibitions in the Petroleum Services Determination provided by GL 124A, which was issued on October 22, 2025 to authorize transactions related to the Caspian Pipeline Consortium (“CPC”) and Tengizchevroil, including CPC and Tengizchevroil transactions involving Lukoil, Rosneft, or entities in which Lukoil or Rosneft own a 50 percent or greater interest. FAQ 1216 also discusses a temporary exception to the Petroleum Services Determination provided by GL 55D, which was issued on June 18, 2025 to authorize certain activities related to the Sakhalin-2 project until December 19, 2025.
OFAC Recent Actions | General License 129 | FAQ 1216