OFAC Issues Temporary General Licenses for Russian-Origin Crude Oil and Petroleum Transactions
The Office of Foreign Assets Control (OFAC) has issued two temporary general licenses to authorize transactions involving Russian-origin crude oil and petroleum products. The first license, General License 133, was issued on March 5, 2026, and the second, General License 134, was issued on March 12, 2026.
General License 133 authorizes certain transactions involving the sale, delivery or offloading of Russian crude oil or petroleum products to India that were loaded onto vessels before 12:01 am ET on March 5, 2026. The general license expires at 12:01 am ET on April 4, 2026.
The conditions for eligible transactions under General License 133 include:
- The delivery or offloading of the crude oil and petroleum products must occur at a port in India;
- The purchaser must be a company incorporated under the laws of India; and
- The crude oil and/or petroleum products must have been loaded onto a vessel prior to the date of the general license (March 5, 2026).
Expansion of Authorized Transactions Under General License 134
OFAC subsequently issued a new general license on March 12, 2026, General License 134, expanding the scope of authorized transactions involving Russian-origin crude oil and petroleum products beyond India to apply globally. Under General License 134, transactions involving Russian origin crude oil and petroleum products are authorized for crude oil and petroleum products loaded onto vessels prior to 12:01 am ET on March 12, 2026, until 12:01am ET on April 11, 2026.
No Reporting Requirements or Sanctions Imposed
The general licenses do not impose any reporting requirements on entities and individuals that rely on it to engage in authorized transactions. The general licenses also extend the authorizations to dealings with Russian-origin crude oil and petroleum products produced by entities that are sanctioned under certain Russian and Iranian sanctions authorities, as well as vessels that are sanctioned under the same programs.
Authorization for Rosneft and Lukoil Vessels
As a result, dealings in Russian-origin crude oil and petroleum products produced by Rosneft and Lukoil (two entities that were designated in October) and on vessels that have been designated by OFAC under applicable authorities (including vessels that are part of the Russian “shadow fleet”) are authorized under General License 133 until 12:01 am ET on April 4, 2026 and under General License 134 until 12:01 am ET on April 11, 2026.
Treasury Secretary’s Statement
Alongside the issuance of General License 133, Treasury Secretary Scott Bessent stated on social media that the general license is a “short term measure” that is designed to “alleviate pressure caused by” the ongoing conflict in Iran and is intended to permit transactions for oil “already stranded at sea.” Secretary Bessent also stated that the Trump Administration anticipates that India will “ramp up purchases of U.S. oil.”
General License 134: A Necessity for Global Energy Markets
Following the issuance of General License 134, Secretary Bessent explained on social media that the temporary authorization is necessary to “promote stability in the global energy markets.”
Original Article: Temporary OFAC General Licenses Authorize Transactions Involving Russian Origin Crude Oil and Petroleum — Bakermckenzie