Russia-related General License 128 - Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia (October 22, 2025)

Date issued: Oct. 23 2025

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TURBOFAC Commentary (104 words)

Notes:

1) Compare Venezuela General License 10 (PdVSA), but this GL is time limited.

2) As of 10-23-25, there were apparently over 100 LUKOIL gas stations operating in the U.S. (https://lukoilamericas.com/en/ForMotorists/PetrolStations). Query whether OFAC would regard LUKOIL has having an “interest” in all such gas stations. It is not clear whether OFAC would consider LUKOIL-branded gas stations that are franchises owned and staffed by independent Americans to be “Public Joint-Stock Company Oil Company Lukoil…has an interest” that are entities “in which Lukoil owns, directly or indirectly, a 50 percent or greater interest, has an interest.”