On 12 March 2026, the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury issued General License No. 134, introducing a temporary, limited, and conditional authorization within the sanctions regime applicable to the Russian energy sector (the “License”).
Pursuant to the License, transactions that are ordinarily incident and necessary to the sale, delivery, or offloading of crude oil or petroleum products of Russian origin are authorized through 11 April 2026, provided that such products were loaded onto vessels prior to 12 March 2026. This authorization applies notwithstanding the fact that such vessels may be blocked pursuant to applicable U.S. sanctions regimes, in particular those established under the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR Part 587) and the Ukraine-/Russia-Related Sanctions Regulations (31 CFR Part 589).
The scope of the License expressly encompasses ancillary services necessary for the safe and orderly execution of such transactions, including, inter alia, vessel docking and anchoring, the protection of crew health and safety, emergency repairs and environmental mitigation measures, as well as related logistical and technical services, such as vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage.
The License further underscores its strictly transitional character, aimed at facilitating the orderly wind-down of pre-existing operations and mitigating risks to maritime safety and global energy supply. It also expressly excludes from its scope any transactions involving Iran, the Government of Iran, or Iranian-origin goods or services prohibited under the Iranian Transactions and Sanctions Regulations (31 CFR Part 560).
This decision is adopted against a backdrop of heightened international geopolitical tensions, characterised by disruptions in hydrocarbon transit, and reflects a divergence from the European Union’s approach, which has expressed its intention to maintain a more restrictive sanctions policy vis-à-vis the Russian Federation.
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