OFAC Issues General License Authorizing Certain Transactions Incident and Necessary to the Sale, Delivery, or Offloading of Russian-Origin Crude and Petroleum Products

On March 12, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License 134 (“GL 134”). 

GL 134 authorizes transactions by U.S. persons “ordinarily incident and necessary” to the sale, delivery, or offloading of Russian-origin crude and petroleum products loaded on vessels on or before 12:01 a.m. Eastern Daylight Time, March 12, 2026.  GL 134 expires at 12:01 a.m. Eastern Daylight Time, April 11, 2026.

As reported in the New York Times, GL 134 is intended to ease immediate energy market disruption from Strait of Hormuz tensions, while leaving in place broader sanctions against the Russian energy sector. 

Before the issuance of GL 134, Executive Orders 14066 and 14071 served as the principal executive authorities that imposed restrictions on U.S. persons with respect to activities in connection with Russian-origin oil and petroleum products. 

E.O. 14066, issued on March 8, 2022, is titled “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts To Undermine the Sovereignty and Territorial Integrity of Ukraine.”  Among other prohibitions, it bans the importation into the United States of Russian-origin crude oil and petroleum products, and prohibits the approval, financing, facilitation, or guarantee by a U.S. person of a foreign transaction that would be prohibited if done by a U.S. person. 

E.O. 14071, issued on April 6, 2022, is titled “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression.” It enables the Secretary of the Treasury, in consultation with the Secretary of State, to designate categories of prohibited services.  Pursuant to that authority, OFAC issued a Determination, effective February 27, 2025, titled “Prohibition on Petroleum Services.”  The Determination generally prohibits the provision by U.S. persons of “petroleum services to any person located in the Russian Federation.”  Excluded from the prohibition, among other things, are “certain covered services related to the maritime transport of crude oil and petroleum products of Russian Federation origin, provided that such crude oil or petroleum products are purchased at or below the relevant determined price caps, as specified in” various OFAC Determinations designed to limit Russian revenues from its energy sector. 

As further defined by OFAC in FAQ 1216, the term “petroleum services” includes shipping and crewing, insurance, financing and brokering, and technical and logistical services connected to petroleum shipments.  The regulatory framework implementing these prohibitions is found principally in the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR Part 587) and in the Ukraine/Russia‑Related Sanctions Regulations (31 CFR Part 589). 

Additional prohibitions are set forth in sanctions programs that generally prohibit all or nearly all forms of commercial activity with various categories of wrongdoers, including proliferators of weapons of mass destruction, global terrorists, and Iranian financial institutions.  OFAC regulations broadly prohibit providing or receiving funds, goods, or services to or from such sanctioned persons and entities.

GL 134 is a narrowly tailored, time-limited measure.  At the same time, the sheer breadth of the sanctioned parties encompassed by the exemption is noteworthy.  GL 134 expressly allows U.S. persons to engage with, among others, malefactors such as proliferators of weapons of mass destruction, global terrorists, and Iranian financial institutions.  This underscores the U.S. government’s desire to urgently address the current oil shortage, even if doing so requires temporarily lifting sanctions imposed against some extremely serious wrongdoers.  

Moreover, allowing U.S. persons to engage with sanctioned parties, even for a limited purpose, poses the risk that U.S. persons might inadvertently engage with sanctioned parties in ways that exceed the scope of permitted interaction. 

Any U.S. person who seeks to participate in activity believed to be authorized by GL 134 would be well-advised to consult experienced sanctions counsel before and while proceeding.