On March 12, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 134, “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 12, 2026.” The general license authorizes transactions “that are ordinarily incident and necessary to the sale, delivery, or offloading of crude oil or petroleum products of Russian Federation origin loaded on any vessel, including vessels blocked under [numerous cited OFAC sanctions programs]” until 12:01 a.m. EDT, April 11, 2026. The general license indicates that such transactions include transactions for the safe docking and anchoring of vessels carrying such crude oil or petroleum products; the preservation of the health or safety of the crew of any such vessel; emergency repairs or environmental mitigation or protection activities relating to any such vessel; and services such as vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage.
Importantly, Russian Federation-origin crude oil and petroleum products subject to this general license includes only those produced by entities sanctioned under the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, or the Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589. As such, in engaging in any Russian oil/petroleum transactions, a close review of this general license is necessary, as is careful screening of the parties involved to determine which sanctions program may apply.