On October 22, 2025, OFAC designated PJSC Lukoil (Lukoil) to increase pressure on Russia's energy sector and degrade Russia's ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions. To support such divestments and further cut off funding to Russia, OFAC issued GL 131, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of Lukoil International GmbH (LIG) or any of LIG's majority-owned subsidiaries. Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors. GL 131 expires on December 13, 2025.
GL 131 does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset. Any contract entered into pursuant to GL 131 must expressly be made contingent upon the receipt of a separate authorization from OFAC. The goal of OFAC's Russia sanctions is to place pressure on Moscow to end its war. As such, Treasury would evaluate any proposed sale of LIG based on factors that support U.S. national security and foreign policy objectives, such as whether the transaction: completely severs ties with Lukoil; blocks funds owed to Lukoil until sanctions are lifted; and does not provide a windfall to Lukoil.
GL 131 also authorizes through December 13, 2025 transactions ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements of LIG entities. This includes transactions ordinarily incident and necessary to performing pre-existing agreements, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations. Such activities could also include payments to employees, suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; or activities associated with maintaining pre-existing capital investments. However, any payment made, directly or indirectly, to LIG entities or any other blocked person must be made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, unless separately authorized by OFAC.
OFAC may revoke GL 131 at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.