On April 17, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia‑related General License No. 134B (“GL 134B”), extending the duration of General License No. 134A, which authorized certain transactions involving crude oil and petroleum products of Russian Federation origin that had already been loaded onto vessels. As with GL 134A, GL 134B authorizes transactions that are ordinarily incident and necessary to the sale, delivery, or offloading of Russian‑origin…
On April 14, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License Nos. 128C and 130A (“GL 128C” and “GL 130A”, respectively), further extending prior authorizations relating to certain transactions involving certain subsidiaries of Public Joint‑Stock Company Oil Company Lukoil (“Lukoil”). As with earlier iterations, these general licenses permit limited, time‑bound transactions to proceed notwithstanding the designation of Lukoil and certain affiliates as Specially Designated Nationals (“SDNs”). We…
On 13 March 2026, the European Commission published a new set of Frequently Asked Questions (“FAQs”, accessible here) clarifying the scope and application of EU sanctions restrictions on the provision of payment services under Article 5b(2) of Council Regulation (EU) No 833/2014, as amended (the “EU Russia Sanctions”). Article 5b(2) of the EU Russia Sanctions prohibits the provision of certain payment services to Russian nationals and natural and legal persons, entities and bodies in Russia…
On 23 January 2026, the European Commission released new FAQ guidance providing clarifications for operators navigating the EU’s expanding Russia sanctions framework. Notably, the European Commission updated their Consolidated FAQs on Sanctions against Russia and Belarus (the “FAQs”, accessible here) with guidance on the Nord Stream transaction ban and the EU’s 19th sanctions package, summarized below. I. Clarifications on the Nord Stream Transaction Ban (Article 5af, Regulation 833/2014) The EU has published dedicated FAQs interpreting…