OFAC amends Russia GL 131H on Lukoil International sale
OFAC issued amended Russia-related General License 131H authorizing negotiation of contingent contracts for the sale of Lukoil International GmbH, and updated related FAQs and Venezuela FAQ 1239.
OFAC extended and amended authorizations for negotiating the divestiture of Lukoil International GmbH, signaling continued managed unwind of Russian energy assets. Amended FAQs clarify permissible maintenance activities and Venezuela-related guidance, affecting energy sector trade finance and M&A advisory.
Amended GLs directly govern permissible Russia energy transactions and require legal review of ongoing contracts and advisory mandates.
Action Required
Review Lukoil-related exposure and update wind-down and contracting procedures to align with GL 131H authorizations and expiration terms.
Lukoil divestiture licensing affects global energy M&A, trade finance and syndicated lending, with material client advisory implications.
Legal and sanctions teams to review GL 131H scope, expiration and FAQ 1224/1225 updates. Confirm Lukoil-related mandates comply. Review Venezuela FAQ 1239 for impact on any legacy exposure.
“OFAC issued Russia GL 131H authorizing negotiation of contingent contracts for the sale of Lukoil International GmbH, amended FAQs 1224/1225 and Venezuela FAQ 1239.”