Russia-related General License 124B - Authorizing Petroleum Services and Other Transactions Related to the Caspian Pipeline Consortium, Tengizchevroil, and Karachaganak Projects (November 14, 2025)

Date issued: Nov. 14 2025

Last substantive commentary amendment:
Nov. 15 2025

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TURBOFAC Commentary (132 words)

Notes:

1) Compare Russia-related GL 121. Paragraph (a) contains the same authorization, but it lasts indefinitely and does not include Sakhalin-2.

2) GL amended on 10-23-25 to account for the designations of Rosneft and Lukoil pursuant to EO 14024.

3) GL amended on 11-14-25 to add Karachaganak to the GL (see https://en.wikipedia.org/wiki/Karachaganak_Field) and to limit the scope of the GL to transactions "related to the operation of" the relevant projects (with an added carveout specifying that the GL does not authorize " transactions for the sale, disposition, or transfer of any interest in the" covered projects. This change appears to imply that the prior iteration of the GL would have authorized transactions to transfer the Lukoil and/or Rosneft interests in the covered projects.