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OFFICE OF FOREIGN ASSETS CONTROL
Russian Harmful Foreign Activities Sanctions Regulations
31 CFR part 587
Ukraine-/Russia-Related Sanctions Regulations
31 CFR part 589
GENERAL LICENSE NO. 135
Authorizing Transactions Related to the Sale, Delivery, Offloading, and Importation of Diesel Fuel of Russian Federation Origin
(a) Except as provided in paragraph (b) of this general license, all transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, or the Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589, that are related to the sale, delivery, offloading, or importation, including importation into the United States, of diesel fuel of Russian Federation origin are authorized through 12:01 a.m. eastern daylight time, April 7, 2027.
(b) This general license does not authorize any debit to an account on the books of a U.S....
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1) Highly unusual GL issued in connection with worldwide diesel supply shock related in part to the Iran and Russia/Ukraine-related conflicts. See https://x.com/WhiteHouse/status/2108634962517786739, https://apnews.com/article/trump-russia-diesel-midterms-12baccc7aade559bf329079b0548c9da and https://x.com/USTreasury/status/2108630834169385310 for further background.
2) The GL covers “that are related to the sale, delivery, offloading, or importation, including importation into the United States, of diesel fuel of Russian Federation origin”. This includes “importation” into all countries, not just the United States (“a temporary general license to allow the supply of Russian diesel to the global market.”).
3) Considering that the GL authorizes against the entirety of the RuHSR and URSR (with no carveouts for any SDNs or any service-specific prohibitions), and that the term...