Russia-related General License 115D - Authorizing Certain Transactions Related to Civil Nuclear Energy

Date issued: Jun. 11 2026

Last substantive commentary amendment:
Sep. 14 2026

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TURBOFAC Commentary (219 words)

Notes:

[9-15-26 – Update – GL useless as it relates to VTB in light of the designation of VTB under EO 13902]

1) Read in conjunction with FAQ # 1203, which provides further clarifying guidance. This GL is unique to OFAC's Russia program. To the extent that "undertaken solely to maintain or support civil nuclear projects initiated before November 21, 2024" raises interpretive issues, there is not much in the way of parallel GLs that could aid in such interpretation.

2) On 1-10-25, OFAC issued Russia-related General License 115A, which adds to the scope of the previous GL 115 the banks included in Russia-related General License 8. GL also amended to change the Directive 2 carveout to accommodate the inclusion of Sberbank on the authorization.
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