OFAC Issues General License Authorizing Certain Transactions Incident and Necessary to the Sale, Delivery, or Offloading of Russian-Origin Crude and Petroleum Products
On March 12, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License 134 (“GL 134”). This narrowly tailored, time-limited measure authorizes transactions by U.S. persons “ordinarily incident and necessary” to the sale, delivery, or offloading of Russian-origin crude and petroleum products loaded on vessels on or before 12:01 a.m. Eastern Daylight Time, March 12, 2026.
GL 134 expires at 12:01 a.m. Eastern Daylight Time, April 11, 2026. As reported in the New York Times, GL 134 is intended to ease immediate energy market disruption from Strait of Hormuz tensions, while leaving in place broader sanctions against the Russian energy sector.
Background on Executive Orders and Sanctions
Before the issuance of GL 134, Executive Orders 14066 and 14071 served as the principal executive authorities that imposed restrictions on U.S. persons with respect to activities in connection with Russian-origin oil and petroleum products. E.O. 14066, issued on March 8, 2022, is titled “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts To Undermine the Sovereignty and Territorial Integrity of Ukraine.” Among other prohibitions, it bans the importation into the United States of Russian-origin crude oil and petroleum products, and prohibits the approval, financing, facilitation, or guarantee by a U.S. person of a foreign transaction that would be prohibited if done by a U.S. person.
E.O. 14071, issued on April 6, 2022, is titled “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression.” It enables the Secretary of the Treasury, in consultation with the Secretary of State, to designate categories of prohibited services. Pursuant to that authority, OFAC issued a Determination, effective February 27, 2025, titled “Prohibition on Petroleum Services.” The Determination generally prohibits the provision by U.S. persons of “petroleum services to any person located in the Russian Federation.”
GL 134 and Its Exclusions
The Determination also excludes from the prohibition certain covered services related to the maritime transport of crude oil and petroleum products of Russian Federation origin, provided that such crude oil or petroleum products are purchased at or below the relevant determined price caps, as specified in various OFAC Determinations designed to limit Russian revenues from its energy sector. As further defined by OFAC in FAQ 1216, the term “petroleum services” includes shipping and crewing, insurance, financing and brokering, and technical and logistical services connected to petroleum shipments.
Risk of Engaging with Sanctioned Parties
GL 134 is a narrowly tailored measure that allows U.S. persons to engage with sanctioned parties, even for a limited purpose. This poses the risk that U.S. persons might inadvertently engage with sanctioned parties in ways that could undermine the effectiveness of sanctions or facilitate illicit activities.
Conclusion
The issuance of GL 134 underscores the U.S. government’s desire to urgently address the current oil shortage, even if doing so requires temporarily lifting sanctions imposed against some extremely serious wrongdoers. As the global energy landscape continues to evolve, it remains essential for policymakers and regulators to balance competing interests and priorities while maintaining effective sanctions regimes that promote national security and stability.
Original Article: OFAC Issues General License Authorizing Certain Transactions Incident and Necessary to the Sale, Delivery, or Offloading of Russian-Origin Crude and Petroleum Products — Jdsupra