Russia-related General License 121 - Authorizing Petroleum Services Related to Certain Projects (January 10, 2025)

Date issued: Jan. 10 2025

Last substantive commentary amendment:
Jun. 19 2025

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TURBOFAC Commentary (124 words)

Notes:

1) Compare Russia-related GL 55C (GL authorizing transactions otherwise prohibited by the price cap prohibition when related to exportation of “ Sakalin-2 byproduct…solely for importation into Japan.” This GL broadly authorizes all transactions otherwise prohibited by the 1-10-25 Prohibition on Petroleum Services Determination “that are related to” Sakalin-2 and two other projects. See generally comments to 1-10-25 Prohibition on Petroleum Services Determination.

2) On 5-15-25, OFAC issued Russia-related GL 124, which is the same authorization as this, but it lasts indefinitely and does not include Sakhalin-2.

3) See Russia-related GL 55D (adding an authorization for Sakhalin-2 that is the same as what is here substantively but lasts until December, 2025).