Russia-related General License (GL) 128B, issued on December 4, 2025, authorizes through April 29, 2026 transactions involving Lukoil International GmbH (LIG), or any of its majority-owned subsidiaries, including Lukoil North America LLC and Lukoil Americas Corporation, (collectively, "LIG Entities") that are ordinarily incident and necessary to the purchase of goods and services from; the provision of goods to; or the maintenance, operation, or wind down of physical retail service stations located outside of the Russian Federation. These transactions may involve the entities that own, lease, franchise, or operate retail service stations, including LIG Entities whose primary business involves the operation of such retail service stations.
GL 128B also authorizes financial institutions, payment processors, and other entities to debit and credit the accounts of LIG Entities involved in the operations of retail service stations to effect transactions authorized by GL 128B. GL 128B expressly authorizes transactions undertaken in the ordinary course of business for retail service stations, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128B or the transfer of funds to any person or account located in the Russian Federation. 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; and legal services and proceedings.
OFAC extended the expiration of GL 128B through April 29, 2026 to mitigate harm to consumers and suppliers seeking to engage in ordinary transactions with retail service stations that involve LIG Entities. OFAC notes that the amendments to GL 128B have no effect on Russia-related GL 131.
Regarding the applicability of General Licenses issued under OFAC's Russia Sanctions Program, non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons. Similarly, non-U.S. persons may rely upon GLs 128B and 131 regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person's activities are consistent with the terms of GLs 128B and 131, including the requirement that no payments may be transmitted to any person or account located in the Russian Federation. For example, non-U.S. persons may process payments relating to the supply of gasoline and provision of electricity and other utility services to Lukoil retail service stations, provided that no funds are transmitted to any blocked persons other than the LIG Entities described in GL 128B or any person or account located in the Russian Federation.