Insights

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued Russia-related General License 133 (“GL 133”) on March 5, 2026 and General License 134 (“GL 134”) on March 12, 2026, authorizing limited transactions involving the sale, delivery, or offloading of Russian-origin crude oil and petroleum products that were already loaded aboard vessels by specified cutoff dates. GL 133 covers cargoes loaded on or before 12:01 a.m. EST on March 5, 2026, and GL 134 covers cargoes loaded on or before 12:01 a.m. EDT on March 12, 2026.

GL 133 is narrower in scope. It authorizes covered transactions through 12:01 a.m. EDT on April 4, 2026, but only where the cargo is delivered or offloaded at a port in India and the purchaser is an entity organized under the laws of India. GL 134, by contrast, authorizes qualifying transactions through 12:01 a.m. EDT on April 11, 2026, and does not include the India-specific port and purchaser conditions found in GL 133.

In both GLs, OFAC makes clear that “ordinarily incident and necessary” transactions may include ancillary maritime and safety-related services, including docking, anchoring, crew safety measures, emergency repairs, environmental mitigation, vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage. Both GLs also state that the covered Russian-origin crude oil and petroleum products include 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.

At the same time, the licenses do not provide broader relief from other sanctions restrictions. Each expressly states that it does not authorize transactions prohibited by other Executive orders or other parts of 31 C.F.R. chapter V not specifically referenced in the license, including otherwise prohibited transactions involving Iran, the Government of Iran, or Iranian-origin goods or services.

OFAC’s issuance of GL 134 just one week after GL 133 signals a continued willingness to use narrow, time-limited measures to manage supply disruption while preserving pressure under relevant Russian sanctions programs. The new GLs highlight the need for careful diligence around cargo timing, transaction scope, and counterparties before proceeding under either authorization.

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If you have questions about the application of OFAC GLs or other sanctions compliance matters, please feel free to contact the attorneys at Torres Trade Law for assistance.

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