Following the Trump Administration’s removal of tariffs on products of India for “buying Russian oil” in February, the Office of Foreign Assets Control (“OFAC”) has issued a temporary general license to authorize transactions that are “ordinarily incident and necessary to the sale, delivery, or offloading of” Russian crude oil and petroleum products to companies in India. General License 133 authorizes certain transactions involving the sale, delivery or offloading of Russian crude oil or petroleum products to India that were loaded onto vessels before 12:01 am ET on March 5, 2026. The general license expires at 12:01 am ET on April 4, 2026.
In addition to the limited duration of the general license, certain conditions also apply to transactions that are eligible for the authorization:
- The delivery or offloading of the crude oil and petroleum products must occur at a port in India;
- The purchaser must be a company incorporated under the laws of India; and
- The crude oil and/or petroleum products must have been loaded onto a vessel prior to the date of the general license (March 5, 2026).
OFAC subsequently issued a new general license on March 12, 2026, General License 134, expanding the scope of authorized transactions involving Russian-origin crude oil and petroleum products beyond India to apply globally. Under General License 134, transactions involving Russian origin crude oil and petroleum products are authorized for crude oil and petroleum products loaded onto vessels prior to 12:01 am ET on March 12, 2026, until 12:01am ET on April 11, 2026.
The general licenses do not impose any reporting requirements on entities and individuals that rely on it to engage in authorized transactions. The general licenses also extend the authorizations to dealings with Russian-origin crude oil and petroleum products produced by entities that are sanctioned under certain Russian and Iranian sanctions authorities, as well as vessels that are sanctioned under the same programs. As a result, dealings in Russian-origin crude oil and petroleum products produced by Rosneft and Lukoil (two entities that were designated in October) and on vessels that have been designated by OFAC under applicable authorities (including vessels that are part of the Russian “shadow fleet”) are authorized under General License 133 until 12:01 am ET on April 4, 2026 and under General License 134 until 12:01 am ET on April 11, 2026.
Alongside the issuance of General License 133, Treasury Secretary Scott Bessent stated on social media that the general license is a “short term measure” that is designed to “alleviate pressure caused by” the ongoing conflict in Iran and is intended to permit transactions for oil “already stranded at sea.” Secretary Bessent also stated that the Trump Administration anticipates that India will “ramp up purchases of U.S. oil.” And following the issuance of General License 134, Secretary Bessent explained on social media that the temporary authorization is necessary to “promote stability in the global energy markets.”
