DEPARTMENT OF THE TREASURY
WASHINGTON, D.C.
OFFICE OF FOREIGN ASSETS CONTROL
Russian Harmful Foreign Activities Sanctions Regulations
31 CFR part 587
GENERAL LICENSE NO. 128B
Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia
(a) Except as provided in paragraph (c) of this general license, all transactions prohibited by Executive Order (E.O.) 14024 involving Lukoil International GmbH (LIG) or any entity in which LIG owns, directly or indirectly, a 50 percent or greater interest, 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, or the maintenance, operation, or wind down of, physical retail service stations located outside of the Russian Federation, are authorized through 12:01 a.m. eastern daylight time, April 29, 2026....
1) This GL expands on two prior iterations (see PDF).
2) Read in conjunction with FAQ # 1225 (interpreting this GL and Russia-related GL 131).
3) LIG is PJSC Lukoil’s primary holding company through which it owns assets outside of Russia.
4) As of 10-23-25, there were apparently over 100 LUKOIL gas stations operating in the U.S. (https://lukoilamericas.com/en/ForMotorists/PetrolStations). Many are not owned by Lukoil, but instead franchises owned by independent non-sanctioned operators whose contractual obligations vis-à-vis Lukoil are unclear. Prior iterations of this GL applied to dealings with “Lukoil Retail Service Stations” which was defined to mean “physical retail service stations located outside the Russian Federation and in existence on or before October 22, 2025 in which (1) Public Joint-Stock Company Oil Company...