Russia-related General License 133, "Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 5, 2026 to India."

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (418 words)

Notes:

1) Extraordinarily rare issued in the midst of the opening of the US/Israeli war on Iran, and evidently aimed at relieving oil supply issues arising from the closure of the Strait of Hormuz. (See https://www.reuters.com/business/energy/indias-reliance-buys-6-mln-barrels-russian-oil-march-sources-say-2026-03-09/, reporting 6 million barrels of Russian oil being purchased pursuant to the GL). The GL is notable for the number of authorities against which it licenses, which is a record as it relates to OFAC GLs. Typically, OFAC only licenses against authorities when there is a clear understanding of the nature of the otherwise prohibited transactions that are licensed, but here OFAC appears to be licensing against every Russia and Iran-related primary sanctions authority “for the avoidance of doubt”. That said, it is likely that there is at least some expected Iranian nexus to the transactions authorized, though this not clear from the...

Welcome!

Welcome!

Russia-related General License 133, "Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 5, 2026 to India."

TURBOFAC Commentary (418 words)