Treasury Unblocks Lukoil Deals Despite Russian Sanctions Drama
Published Date: 9/30/2026
Rule
Summary
The Treasury’s Office of Foreign Assets Control (OFAC) published three updated licenses (131E, 131F, and 131G) that let certain businesses negotiate and enter contracts related to Lukoil International GmbH despite existing sanctions. These licenses replace each other in sequence from April to June 2026, allowing specific transactions that were previously blocked. If you’re involved with Lukoil or its affiliates, these changes could impact your deals and deadlines through May 2026 and beyond.
Analyzed Economic Effects
3 provisions identified: 2 benefits, 1 costs, 0 mixed.
Allowed Negotiations to Sell Lukoil Unit
OFAC authorized businesses to negotiate and enter contingent contracts to sell Lukoil International GmbH ("LIG") or entities in which LIG owns a 50 percent or greater interest. These authorizations were issued as General License 131E (through 12:01 a.m. EDT May 30, 2026), GL 131F (through 12:01 a.m. EDT June 27, 2026), and GL 131G (through 12:01 a.m. EDT July 25, 2026). The contracts must be expressly contingent on separate OFAC authorization before performance.
Maintenance and Wind‑Down Transactions Allowed
OFAC allowed transactions that are ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements of LIG Entities. These maintenance/wind‑down authorizations match the GL dates: through 12:01 a.m. EDT May 30, 2026 (GL 131E), June 27, 2026 (GL 131F), and July 25, 2026 (GL 131G). The GLs also permit use, debit, or credit of blocked accounts of LIG Entities for those maintenance transactions.
Key Restrictions Remain in Place
Each general license explicitly does not authorize the unblocking of property except as allowed for maintenance in paragraph (c), does not authorize transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations (including dealings with blocked persons not described in paragraph (a)), and does not authorize transfers of funds to any person or account located in the Russian Federation. Those limits apply despite the temporary authorizations for negotiation, contingent contracts, and maintenance.
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Key Dates
Department and Agencies
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