The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has amended two Russia-related General Licenses (“GLs”) —131A and 128B—affecting (i) contingent contract negotiations for acquisition of and maintaining/winding down transactions with certain Lukoil entities and (ii) retail transactions with ex-Russia Lukoil service stations. More information regarding each GL is below and our blog post regarding prior iterations of these GLs can be found here.
Amended GL 131A
On December 10, 2025, OFAC issued amended GL 131A, “Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities.” GL 131A authorizes, through 12:01 am EDT on January 17, 2026, all transactions that are ordinarily incident and necessary to:
- the negotiation of and entry into contracts with Lukoil International GmbH (“LIG”) or any entity it owns by 50% or more (collectively, “LIG Entities”) for the sale, disposition, or transfer of any LIG Entities, provided that the performance of any such contract is made expressly contingent upon the receipt of separate authorization from OFAC; and
- the maintenance or wind down of operations, contracts, or other agreements of LIG Entities.
Authorization of these transactions was previously set to expire on December 13, 2025 under the previous GL 131. GL 131A also added language that (i) authorizes blocked accounts of LIG Entities to be used, debited, or credited for the GL 131A-authorized maintenance/wind-down transactions and (ii) prohibits the transfer of funds to any person or account located in Russia.
Amended GL 128B
On December 4, 2025, OFAC issued amended GL 128B, “Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia.” GL 128B authorizes certain transactions involving LIG Entities, including Lukoil North America LLC and Lukoil Americas Corp., as long as those transactions “are ordinarily incident and necessary to the purchase of goods and services from, or the maintenance, operation, or wind down of, physical retail service stations located outside” Russia. These transactions are authorized through 12:01 am EDT on April 29, 2026.
Authorization of these transactions was set to expire on December 13, 2025 under the previous GL 128A. GL 128B also clarifies its scope to only include physical retail service stations owned by LIG.
OFAC also issued a new Frequently Asked Question (“FAQ”) related to the amended GL. FAQ 1255 clarifies that the scope of transactions authorized by GL 128B include those that may involve the entities that own, lease, franchise or operate retail service stations, including LIG entities “whose primary business involves the operation of such retail service stations.” GL 128B authorizes financial institutions, payment processors, and other entities to debit and credit the accounts of LIG Entities involved in the operations of retail service stations to effect transactions authorized by GL 128B.
In FAQ 1255, OFAC stated that the expiration of GL 128B was extended through April 29, 2026 to mitigate harm to consumers and suppliers seeking to engage in ordinary transactions with retail service stations that involve LIG Entities.
The authors acknowledge the assistance of Ryan Orange with the preparation of this blog post.
