OFAC General License Authorizes Sales to India of Russian Oil Loaded Before March 5
On Thursday, March 5, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC“) issued Russia General License 133 (GL 133). GL 133 authorizes transactions “ordinarily incident and necessary to the sale, delivery, or offloading” of Russian-origin crude oil and petroleum products (collectively, “products”) to India, subject to certain conditions.
The delivery or offloading must occur at an Indian port. The purchaser must be an entity organized under Indian law. Critically, GL 133 applies only to Russian-origin products loaded “on or before 12:01 a.m. eastern standard time, March 5, 2026.” It authorizes transactions related to such already-loaded products “through 12:01 a.m. eastern daylight time, April 4, 2026.”
Transactions with Sanctioned Entities and Vessels
Notably, the General License explicitly authorizes transactions where Russian-origin products are “produced by entities sanctioned” under certain Russian and Iranian sanctions programs, and/or loaded onto “vessels blocked” under these programs. GL 133 appears therefore to authorize both shipments on sanctioned “shadow fleet” vessels and sales of products produced by sanctioned entities, including Rosneft and Lukoil—Russia’s two largest oil companies, which the United States designated last October.
Background and Context
The issuance of GL 133 comes a month after President Trump announced the United States would reduce tariffs on India, citing India‘s commitment to “stop buying Russian oil.” He explained that India‘s decision to cease Russian oil imports would help end the war in Ukraine. In a social media post on March 5, 2026, Treasury Secretary Bessent said that GL 133 is designed as a “short-term measure” to “enable oil to keep flowing to market,” authorizing transactions “involving oil already stranded at sea.” He noted that “India is an essential Partner of the United States” and that GL 133 will help “alleviate pressure caused by Iran’s attempt to take global energy hostage.”
Conclusion
The issuance of General License 133 marks a significant development in the ongoing saga of international sanctions and trade relations. As the global energy landscape continues to evolve, it remains to be seen how this new license will impact the flow of Russian oil and petroleum products to India and beyond.
Original Article: OFAC General License Authorizes Sales to India of Russian Oil Loaded Before March 5 | Sullivan & Cromwell LLP — Sullcrom