Russia-related General License 131 - Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities (November 14, 2025)

Date issued: Nov. 14 2025

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TURBOFAC Commentary (288 words)

Notes:

1) Lukoil International GmbH is the primary holding company through which Lukoil holds its non-Russian assets, the acquisition of which by Gunvor SA (Switzerland) was proposed prior to the issuance of this GL and rejected by the USG (see https://www.lukoil.com/PressCenter/Pressreleases/Pressrelease/lukoil-receives-offer-from-gunvor-to-purchase and https://www.reuters.com/business/energy/gunvor-says-withdraws-bid-buy-assets-russian-energy-firm-lukoil-2025-11-06/. While such transaction appears to have been within the scope of paragraph (a) of Russia GL 127 if it had been concluded in prior to the Nov. 21 expiration of that GL, this GL is valid through Dec. 13, 2025, though it comes with two key proviso that “the performance of any such contract is made expressly contingent upon the receipt of separate authorization from the Office of Foreign Assets Control”.

2) The GL also authorizes “all transactions prohibited by E.O. 14024 that are...