Russia-related General License 134, "Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 12, 2026."

Date issued: Mar. 12 2026

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TURBOFAC Commentary (121 words)

Notes:

1) Compare and see comments to Russia-related GL 133 (similar GL issued a week prior, but limited to oil purchased by Indian entities for delivery to India). As with the India GL, this is an extraordinarily, first-of-its-kind GL authorizing all transactions otherwise prohibited to virtually every Russia or Iran-related sanctions authority ordinarily incident to Russian oil floating as of the date the GL was issued. The GL would, conceivably, authorize the purchase of oil above the price cap, floating on an SDN vessel sanctioned pursuant to the GTSR, which is sold by an SDN that requires payment into an SDN bank. The GL is so broad on its face that it raises few interpretive issues.