What activities do [Russia-related General License 128C](https://ofac.treasury.gov/media/935496/download?inline) and [General License 131G](https://ofac.treasury.gov/media/936301/download?inline) authorize related to Lukoil International GmbH (LIG)?
OFAC's answer
OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries ("LIG Entities"): [GL 128C](https://ofac.treasury.gov/media/935496/download?inline) and [GL 131G](https://ofac.treasury.gov/media/936301/download?inline). The GLs are similar but have different expiration dates and terms as each serves a different purpose. - To mitigate the effects of Lukoil's OFAC designation on retail consumers, OFAC issued on December 4, 2025 [GL 128B](https://ofac.treasury.gov/media/934791/download?inline) to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation. OFAC subsequently issued [GL 128C](https://ofac.treasury.gov/media/935496/download?inline) to extend the existing authorization until October 29, 2026. - To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities. OFAC subsequently issued GLs 131B, 131C, 131D, 131E, 131F, and [131G](https://ofac.treasury.gov/media/936301/download?inline) to extend the existing authorization until July 25, 2026. Please see [Frequently Asked Question 1224](https://ofac.treasury.gov/faqs/1224) for additional information on authorizations regarding negotiations for the sale of LIG Entities. [GL 128C](https://ofac.treasury.gov/media/935496/download?inline) and [GL 131G](https://ofac.treasury.gov/media/936301/download?inline) expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in [GL 128C](https://ofac.treasury.gov/media/935496/download?inline) and [GL 131G](https://ofac.treasury.gov/media/936301/download?inline). Transactions undertaken in the ordinary course of business may involve (but are not limited to): supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. Also, both [GL 128C](https://ofac.treasury.gov/media/935496/download?inline) and [GL 131G](https://ofac.treasury.gov/media/936301/download?inline) authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations. Both [GL 128C](https://ofac.treasury.gov/media/935496/download?inline) and [GL 131G](https://ofac.treasury.gov/media/936301/download?inline) also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation. Non-U.S. persons generally do not risk exposure to U.S. sanctions under [E.O. 14024](https://ofac.treasury.gov/media/57936/download?inline) for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by [GL 128C](https://ofac.treasury.gov/media/935496/download?inline) and [GL 131G](https://ofac.treasury.gov/media/936301/download?inline). Similarly, non-U.S. persons may rely upon [GL 128C](https://ofac.treasury.gov/media/935496/download?inline) and [GL 131G](https://ofac.treasury.gov/media/936301/download?inline) regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person's activities are consistent with the terms of [GL 128C](https://ofac.treasury.gov/media/935496/download?inline) and [GL 131G](https://ofac.treasury.gov/media/936301/download?inline), including the requirement that no payments may be transferred to any person or account located in the Russian Federation. Date Updated: June 25, 2026