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 previously blogged about these OFAC authorizations here, here, and here.
GL 128C (Lukoil Retail Service Stations Outside Russia)
This development amends GL 128B to extend the expiration of the license to 12:01 am EDT on October 29, 2026 (from April 29, 2026). The extension continues OFAC’s incremental approach to authorizing transactions that are ordinarily incident and necessary to the purchase of goods and services from, or the maintenance, operation, or wind‑down of, Lukoil retail service stations located outside of Russia. OFAC concurrently published an updated FAQ 1225. GL 128C does not amend the substantive provisions of prior versions of GL 128, which are designed to mitigate disruption to consumers, suppliers, and counterparties engaging in ordinary commercial activity with ex‑Russia Lukoil retail operations.
GL 130A (Transactions with Certain Lukoil Entities in Bulgaria)
GL 130A extends earlier authorizations relating to transactions involving specified Lukoil‑affiliated entities incorporated in Bulgaria, and entities in which they hold, directly or indirectly, a 50% or greater interest. As with GL 128C, GL 130A extends the expiration of the authorization from April 29, 2026 to 12:01 am EDT on October 29, 2026. As with GL 128C, GL 130A does not amend the substantive provisions of the prior version of GL 130.
The author acknowledges the assistance of Avi Toltzis in the preparation of this blog post.
