Russia-related General License 126 - Authorizing the Wind Down of Transactions Involving Rosneft or Lukoil (October 22, 2025)

Date issued: Oct. 23 2025

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TURBOFAC Commentary (120 words)

Notes:

1) This is a standard wind-down general license covering multiple blocked entities, authorizing the processing of underlying transactions even where those underlying transactions do not involve U.S. persons (see e.g., FAQ 807), but not including authorizations for the "maintenance" of activities. Compare Russia-related GL 88.

2) Refer to the Research System for documents dealing with the scope of the types of transactions that qualify for "wind down" GLs such as this. See in particular Examples of Transactions Deemed to be, and not to be, Within the Scope of the Standard "Wind-down" and "Maintenance" GLs.

3) Russia-related GL 124A, Russia-related GL 127 and Russia-related GL 128were issued concurrently and apply to the same entities.