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1225. What activities do Russia-related General Licenses 128B and 131 authorize?
Russia-related General License (GL) 128B, issued on December 4, 2025, authorizes through April 29, 2026 transactions involving Lukoil International GmbH (LIG), or any of its majority-owned subsidiaries, including Lukoil North America LLC and Lukoil Americas Corporation, (collectively, "LIG Entities") that are ordinarily incident and necessary to the purchase of goods and services from; the provision of goods to; or the maintenance, operation, or wind down of physical retail service stations located outside of the Russian Federation. These transactions may involve the entities that own, lease, franchise, or operate retail service stations, including LIG Entities whose primary business involves the operation of such retail service stations.
GL 128B also authorizes financial institutions, payment processors, and other entities to debit and credit the accounts of LIG Entities involved in the operations of retail service stations to effect...
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1) See comments to Russia-related GL 128 for discussion on how this FAQ relates to the scope of Russia-related GL 128.
2) With respect to the secondary sanctions safe harbor guidance, which applies to this GL and Russia-related General License 131 OFAC provides the standard guidance that “non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons” (compare FAQ # 980), and specifies further that the GLs may be relied upon by FFIs engaging in otherwise sanctionable activity even if not operating “blocked accounts” (i.e. paragraph (b) provides authorization to use blocked accounts in connection with authorized activities, it does not require that). The FAQ is notable for specifying that, in order for the...