On December 4, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control issued general license (“GL”) 128B under the Russian Harmful Foreign Activities Sanctions Regulations (“RuHSR”), 31 CFR part 587. GL 128B temporarily authorizes transactions with Lukoil International GmbH (LIG) or any entity in which LIG owns a 50 percent or greater interest, including Lukoil North America LLC and Lukoil Americas Corporation, (collectively, “LIG Entities”) that relate to the purchase of goods and services from, the maintenance, operation or wind down of physical retail services stations located outside of Russia. These transactions are authorized until April 29, 2026.
On the same day, OFAC amended Frequently Asked Question 1225 to provide an overview of the provisions in Russia-related General Licenses 128B and 131, which temporarily authorize certain transactions and agreements with LIG entities. In FAQ 1225, OFAC explains that GL 128B applies to transactions involving entities that own, lease, franchise, or operate retail services stations only if the transactions are undertaken in the ordinary course of business and do not involve any other blocked persons or accounts located in Russia. According to OFAC, the permitted transactions include lease payments, insurance payments, employee payroll, information technology services, and legal services and proceedings. FAQ 1225 also provides that the amendments to GL 128B have no effect on GL 131.
OFAC Recent Action | General License 128B | FAQ 1225