1224. What activities does OFAC General License 131, "Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities," authorize?
On October 22, 2025, OFAC designated PJSC Lukoil (Lukoil) to increase pressure on Russia's energy sector and degrade Russia's ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions. To support such divestments and further cut off funding to Russia, OFAC issued GL 131, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of Lukoil International GmbH (LIG) or any of LIG's majority-owned subsidiaries. Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors. GL 131 expires...
1) FAQ interprets Russia-related GL 131. The GL confirms that the generally standard “maintenance or wind down of operations, contracts, or other agreements” language in GL 131 covers “transactions ordinarily incident and necessary to performing pre-existing agreements, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations”. Compare Examples of Transactions Deemed to Be, and Not to Be, Within the Scope of the Standard “Wind-Down” and “Maintenance” GLs, and query whether, when linked to “pre-existing agreements,” such transactions are also covered under the standard wind down GL 126. “Maintenance” GLs. The FAQ also specifies that covered “wind down or maintenance” transactions can “include payments to employees, suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; or activities associated with maintaining pre-existing capital investment”.
2) OFAC...