The U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) issued Russia-related General License 134 (“GL 134”) yesterday, which temporarily authorizes the delivery and sale of Russian-origin crude oil and petroleum products that are already on the water as of March 12, 2026.  It is understood the policy intent is to contain the oil prices that rose significantly after the closure of the Strait of Hormuz by Iran.

GL 134 contains broad authorizations, covering activities such as the “sale, delivery, or offloading of such crude oil or petroleum products include transactions for the safe docking and anchoring of vessels carrying such crude oil or petroleum products; the preservation of the health or safety of the crew of any such vessel; emergency repairs or environmental mitigation or protection activities relating to any such vessel; and services such as vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage.”

Importantly, GL 134 also authorizes dealings with vessels and entities normally sanctioned under the OFAC programs listed at the top of the license, including the Russia program.  From an activity-based sanctions perspective, GL 134 also temporarily pauses the U.S. price cap, which was implemented under Executive Order 14071 of the Russian Harmful Foreign Activities Sanctions Regulations, and is one of the programs that is temporarily relaxed by the general license.  Notably, the EU / UK measures, however, including the application of the price cap and any sanctions on designated persons – still remain.  Practically, this means that parties with EU / UK touchpoints may still be exposed to sanctions under the EU / UK regimes if the applicable price cap is not complied with or if the transaction involves a vessel or entity sanctioned by those regimes.

There are two important limitations to GL 134.  The first is that it only applies to products loaded on the vessel on or before 12:01 a.m. Eastern Daylight Time, March 12, 2026.  The license expires on April 11, 2026.  The second is that GL 134 does not authorize activities or transactions that are prohibited by a legal authority other than the ones explicitly mentioned in the GL.  For example, it would not authorize transactions that are otherwise prohibited by OFAC’s Venezuela, DPRK, or Cuba programs.  Moreover, except as authorized by paragraph (a) of the GL, transactions or activities that involve Iran, the Government of Iran, or Iranian-origin goods or services remain prohibited.