License No. MUL-2025-1355297-7

Date issued: Sep. 30 2025

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TURBOFAC Commentary (216 words)

Notes:

1) This SL authorizes certain dealings with an SDN oil refiner in Serbia that was added to the SDN List (pursuant to EOs 14024 and 13662) due to Russian government ownership. This is the seventh iteration of the SL, which was extended several times pending negotiations for the divestment by the Russian shareholders. The SL is notable as an example of OFAC’s implementation of a licensing policy concerning the continued operation of Russian-owned energy assets in allied or neutral countries where such assets are critical for the host country’s energy needs, as is the case with NIS (see generally https://en.wikipedia.org/wiki/Naftna_Industrija_Srbije).

2) One notable aspect of the SL is that the “Licenses” include all “U.S. persons,” such that the SL operates as a sort of GL...