What Lukoil General License 131H allowed, and how OFAC replaced it.
A familiar license number can mask a changed deadline. What GL 131H authorized for Lukoil International and its majority-owned entities, and what it never did.
Sanctions · 25 Sep 2026
OFAC issued Russia-related General License 131H on July 24, 2026, for specified transactions involving Lukoil International GmbH (LIG) and its majority-owned entities. As issued, it allowed certain negotiations and maintenance or wind-down activity through 12:01 a.m. Eastern Daylight Time on August 22, 2026. GL 131H did not run to that date: OFAC replaced it on August 20, 2026 with GL 131I, and replaced GL 131I on September 18, 2026 with GL 131J. This article explains the July instrument; it is not present authorization.
What happened
OFAC designated Lukoil in October 2025. GL 131H covered LIG and entities in which LIG owned a 50 percent or greater interest, directly or indirectly, individually or in the aggregate. It replaced GL 131G effective July 24.
Paragraph (a) authorized transactions ordinarily incident and necessary to negotiating and entering into contracts with Lukoil or its affiliates for the sale, disposition, or transfer of LIG or an LIG Entity. Performance of each such contract had to be made expressly contingent on separate OFAC authorization. Its note gave examples of contingent contracts, including executory contracts, bids, and binding memoranda of understanding. Negotiation authority did not itself permit completing a sale.
Paragraph (b) authorized transactions ordinarily incident and necessary to maintaining or winding down operations, contracts, or other agreements of LIG Entities. Paragraph (c) permitted blocked accounts of LIG Entities to be used, debited, or credited for paragraph (b) transactions. As issued, both principal authorizations ran to 12:01 a.m. EDT on August 22, 2026. Two days before that date, GL 131I replaced and superseded GL 131H in its entirety and extended both authorizations to 12:01 a.m. EDT on September 19, 2026.
The limits in the July text
Paragraph (d) excluded other unblocking, transactions with other blocked persons unless separately authorized, and transfers to persons or accounts in Russia. “Ordinary business” alone did not override those exclusions.
The words “ordinarily incident and necessary” also did work. A supplier needed to match each payment, service, or contract to a permitted activity and test the conditions and excluded parties. The blocked-account provision did not make every payment permissible.
OFAC's later FAQ 1225 gives examples of ordinary-course transactions that may fall within the GL 131 series when their terms are met: fuel and lubricant supply, leases, insurance, property maintenance, payroll, information technology, and payments to suppliers and other partners. The examples illustrate scope; they do not substitute for the text of the license in force on the transaction date.
A different retail-station license
Separate GL 128C addressed certain activity involving physical Lukoil retail service stations outside Russia and had a different expiration date. A terminal or trading-entity transaction did not gain that longer window merely because the counterparty was a LIG entity. Each transaction needed its own scope check.
What this means for you
A license register can record the ownership chain, transaction type, license version and dates, separate authorizations, and payment exclusions. Tie each conclusion to the transaction date. When OFAC replaces a license, check the successor text.
The register should also identify the person responsible for noticing an amendment or replacement, because a familiar license number can mask a changed deadline, covered activity, or exclusion. A prior approval should not be copied to a later transaction without checking those differences.
GL 131H was in force from July 24 until August 20, 2026, when GL 131I replaced it. On September 18, 2026, GL 131J replaced GL 131I and extended the negotiation and maintenance or wind-down authorizations through 12:01 a.m. EDT on October 22, 2026, with the same exclusions. OFAC's FAQ 1225 lists the full series in order, ending 131H, 131I and 131J. A transaction on or after August 20 is therefore tested against GL 131I (August 20 to September 17) or GL 131J (from September 18), not GL 131H. GL 131J carries its own deadline, so check whether OFAC has issued a further successor before relying on it. Current facts, counterparties, and authorization must be checked separately.
Building the program you can actually stand behind
Keep a record of the authorization for each relationship, who checked it, and when to check again. The question is whether the activity fit the license version effective when it occurred.
Contact Zimmermann Law to discuss company-side U.S. sanctions questions involving ownership and general-license scope.
Sources: OFAC General License 131H (July 24, 2026), including paragraphs (a)–(e) and the note to (a); OFAC General License 131I (Aug. 20, 2026), paragraphs (a), (b) and (e); OFAC General License 131J (Sept. 18, 2026), paragraphs (a), (b), (d) and (e); OFAC September 18, 2026 issuance of GL 131J; OFAC FAQ 1224 and FAQ 1225 (updated Sept. 18, 2026). GL 131I, GL 131J and FAQ 1225 checked October 8, 2026. GL 128C is described only at a high level from FAQ 1225; its full text was not independently reread in this pass.
This post is for general information and is not legal advice.
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