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OFAC ·

OFAC issues GL 131E for Lukoil contract negotiations

Sanctions teams may negotiate defined Lukoil sale contracts under GL 131E only

Trade & Tariffs Oil & Gas Sanctions
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OFAC issued Russia-related General License 131E authorising specified transactions to negotiate contingent contracts for the sale of Lukoil International GmbH.
Why it matters
Lukoil sale negotiations now sit inside a narrow OFAC carve-out within Russia sanctions. Activity outside the defined scope remains prohibited. Amendments to FAQs 1224 and 1225 clarify scope boundaries and compliance expectations.
Implications
  • — Sanctions compliance teams must ensure all Lukoil-related negotiation and contract structuring activity falls strictly within GL 131E scope — activity outside defined authorization remains prohibited and subject to enforcement
  • — Legal and trade-finance teams must structure contingent contracts and associated payment flows to align with GL 131E conditions — mis-scoped transactions risk blocking or sanctions violations
Who is affected
  • — Sanctions compliance teams
  • — Legal teams structuring cross-border transactions
  • — Trade-finance teams managing restricted jurisdiction flows
What to watch
  • — Further OFAC amendments altering GL 131E scope or applicability
  • — Regulatory or enforcement guidance clarifying treatment of contingent contracts under sanctions regimes

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