On April 14, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended two general licenses to continue authorizing limited transactions under previous sanctions involving Russia’s Lukoil operations.
Russia-related General License 128C, “Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia.” This amended general license extends until October 29, 2026, all transactions that are ordinarily incident and necessary to the purchase of goods and services from, or the maintenance, operation, or wind down of Lukoil retail service stations located outside of Russia.
Russia-related General License 130A, “Authorizing Transactions Involving Certain Lukoil Entities in Bulgaria.” This amended general license authorizes until October 29, 2026, transactions with four Lukoil entities incorporated in Bulgaria, and any entity in which such entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
Certain transactions otherwise prohibited by the Russia Harmful Foreign Activities Sanctions regulations remain unauthorized and, therefore, each of these general licenses requires close analysis. For additional background information on the sanctions against Lukoil, see Thompson Hine Updates of October 23, 2025 and November 17, 2025.