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Sanctions Targets

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On April 14, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two new general licenses (“GLs”) — GL 56 and GL 57, which further ease longstanding US sanctions targeting Venezuela. OFAC also issued a new Frequently Asked Question (“FAQ”) to clarify the scope of the reporting requirements included in several Venezuela-related GLs. These GLs address certain gaps in the previous sanctions framework and removal of certain restrictions by broadening the…

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 March 20, 2026, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Iran-related General License U (“GL U”), “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Iranian-Origin Loaded on Vessels as of March 20, 2026.” One day earlier, on March 19, 2026, OFAC issued Russia-related General License 134A (“GL 134A”), “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on…