GL-128C

Summary

General License 128C authorizes transactions otherwise prohibited by E.O. 14024 that involve Lukoil International GmbH (LIG) and its majority-owned subsidiaries, including Lukoil North America LLC and Lukoil Americas Corporation, to the extent those transactions are ordinarily incident and necessary to purchasing goods and services from, or maintaining, operating, or winding down physical retail service stations located outside of Russia. Blocked accounts of LIG Entities may be used, debited, or credited for these authorized transactions. This license replaces and supersedes General License 128B dated December 4, 2025, effective April 14, 2026.

Authorized activities

• Purchase of goods and services from Lukoil retail service stations located outside of Russia
• Maintenance of physical retail service stations located outside of Russia involving LIG Entities
• Operation of physical retail service stations located outside of Russia involving LIG Entities
• Wind down of physical retail service stations located outside of Russia involving LIG Entities
• Use, debit, or credit of blocked accounts of LIG Entities for the above authorized transactions

Conditions

Does not authorize: transactions prohibited by Directive 2 under E.O. 14024 (correspondent or payable-through accounts); transactions prohibited by Directive 4 under E.O. 14024 (Central Bank of Russia, National Wealth Fund, or Ministry of Finance of Russia); transactions otherwise prohibited by the RuHSR involving any blocked person other than the LIG Entities described in paragraph (a), unless separately authorized; or the transfer of funds to any person or account located in the Russian Federation.