On March 12, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued Russia-related General License 134 (GL 134) authorizing, until April 11, 2026, transactions relating to the sale, delivery, and offloading of Russian-origin crude oil and petroleum products loaded on vessels as of March 12, 2026. The general license follows recent disruptions to global oil supply arising from the ongoing conflict in the Middle East.
GL 134 authorizes, until April 11, 2026, all transactions otherwise prohibited under Russia-, Iran-, terrorism-, and weapons of mass destruction-related sanctions programs that are ordinarily incident and necessary to the sale, delivery, or offloading of Russian-origin crude oil or petroleum products loaded on any vessel on or before 12:01 a.m. EDT on March 12, 2026. Notably, Russian-origin crude oil and petroleum products produced or transported by sanctioned entities or vessels blocked under the listed authorities (including all Russia-related sanctions), are expressly included within the scope of GL 134.
Transactions covered by GL 134 as “ordinarily incident and necessary” to the sale, delivery, or offloading of crude oil or petroleum products include transactions necessary for safe docking and anchoring, crew health and safety, emergency repairs, environmental mitigation, and a broad range of vessel services, including management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage.
Link to Key Limitations Key Limitations
Although GL 134 is broad in scope, it includes certain key limitations. Most critically, GL 134 only applies to cargo loaded on or before 12:01 a.m. EDT on March 12, 2026. Accordingly, cargo loaded after that time is not covered by the GL. In addition, GL 134 does not authorize any transaction or activity involving Iran, the Government of Iran, or any Iranian goods or services otherwise prohibited by the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560, except to the limited extent that such transactions fall within the scope of GL 134’s authorizations described above. GL 134 likewise does not authorize transactions prohibited by other sanctions programs not listed in the GL (such as the Cuba, North Korea, and Venezuela sanctions programs).
Parties intending to engage in the shipping, trading, financing, or insuring of Russian-origin crude oil or petroleum products pursuant to GL 134 should carefully consider all parties directly or indirectly involved in the transaction, as well as any Iran-related nexus, that may be outside the scope of the authorization. In addition, parties relying upon GL 134 should maintain records of loading dates, vessel details, and all transaction documentation to support and document compliance with GL 134 and the relevant sanctions programs.
Cleary’s sanctions team is continuing to monitor the situation in the Middle East and its impacts on U.S. sanctions policy.