The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has amended two Russia-related General Licenses (“GLs”) – 55E and 115C – that authorize certain transactions related to crude oil originating from the Sakhalin-2 project and certain transactions with Russian entities related to civil nuclear energy. OFAC also updated several frequently asked questions (“FAQs”).
Amended GLs 55E and 115C
The amended GL 55E, “Authorizing Certain Services Related to Sakhalin-2,” authorizes, through 12:01 am EDT on June 18, 2026:
- certain transactions with Sakhalin-2, an oil and gas development business based in Russia, as long as the Sakhalin-2 byproduct is solely for importation into Japan; and
- certain transactions involving Gazprombank Joint Stock Company (“Gazprombank”) or any entity in which Gazprombank owns, directly or indirectly, a 50% or greater interest, that are related to the Sakhalin-2 project, including such transactions involving Sakhalin Energy LLC.
The amended GL 115C, “Authorizing Certain Transactions Related to Civil Nuclear Energy,” extends authorization of certain transactions involving one or more of the entities listed in the GL, and any entity in which they own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, through 12:01 am EDT on June 18, 2026.
Amended Frequently Asked Questions
OFAC also amended FAQs 967, 978, 999, 1011, 1117, 1182, 1203, and 1216. These FAQs were mostly amended to reflect the reissued GLs 55E and 115C.
OFAC also amended FAQ 1225, which was covered in this previous blog post on recently amended GLs 128B and 131A. Amended FAQ 1225 expands the scope of transactions authorized by GL 131A to include payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. It also clarifies that both GL 128B and GL 131A authorize financial institutions, payment processors, and other entities to use debit, and credit the accounts of the relevant entities that are part of Lukoil International GmbH (“LIG”) to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russia.
The author acknowledges the assistance of Ryan Orange with the preparation of this blog post.
