A diesel license with a precise cutoff: What OFAC's GL 135 means for fuel traders
GL 135 authorizes Russian-origin diesel transactions under two specified sanctions programs through 12:01 a.m. EDT on April 7, 2027. The payment path must also be assessed against its account-debit exclusion.
Sanctions · 10 Oct 2026
A diesel contract can move through several decisions before the fuel reaches its destination: sale, transport, offloading, importation and payment. A company assessing OFAC's new General License 135 needs to connect those steps to the license's scope and deadline. A bank reviewing the payment needs the same transaction description, plus the account details relevant to the license's exclusion. For fuel traders, carriers, insurers and their company counsel, the useful starting point is the actual planned shipment and funds movement, rather than an assumed permission for Russia-related trade generally.
What happened
On October 9, 2026, OFAC announced Russia-related General License 135, “Authorizing Transactions Related to the Sale, Delivery, Offloading, and Importation of Diesel Fuel of Russian Federation Origin.” The one-page instrument contains an authorization in paragraph (a) and an account-debit exclusion in paragraph (b).
General License 135, paragraph (a), authorizes all transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. part 587, or the Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. part 589, that are related to the sale, delivery, offloading or importation of diesel fuel of Russian Federation origin. It expressly includes importation into the United States. That authorization is subject to paragraph (b) and runs through 12:01 a.m. eastern daylight time on April 7, 2027.
Those regulatory references identify the license's stated scope. This article reviews GL 135 as issued; it does not provide a complete review of the current regulatory parts or determine whether a particular transaction is permitted under every applicable authority.
Match the activity to the license
The instrument identifies the fuel's origin and four categories of activity: sale, delivery, offloading and importation. Its language is transactions “related to” those activities. The company reviewing a proposal should therefore describe the cargo and the actual work rather than relying only on a contract label or the license number.
Firm control observation: Create a short transaction description covering the fuel, seller, buyer, carrier, destination, services and payment arrangements. For a carrier or insurer, identify the transport work or coverage being assessed and its relationship to the specified diesel activity. For a bank, use that same description when examining the proposed funds movement. These are practical review steps, not additional conditions inserted into GL 135.
The instrument is directed to diesel fuel of Russian Federation origin. It does not establish a permission for every petroleum product or every Russia-related commercial activity. This article also makes no determination about other U.S. sanctions programs, export requirements, customs rules or foreign law. A license identifying two regulatory programs should be assessed within that stated scope.
Treat the deadline as a transaction planning fact
The precise cutoff is 12:01 a.m. EDT on April 7, 2027. Recording only “April 7” would omit the time and could be mistaken for an authorization lasting through the day's end. The instrument uses eastern daylight time; a team working in another time zone should record the equivalent local time accurately while retaining OFAC's original wording.
Firm control observation: Map the intended sale, transport, offloading, importation and payment dates against the exact cutoff. Allow for port congestion, changed routes and delayed payment processing when management assesses the commercial timetable. This planning margin is the firm's recommendation, not a separate license requirement.
A contract signed before the cutoff does not, by itself, answer which authority would cover a later transaction. If a delivery or payment may occur afterward, treat the authority for that step as a question requiring a separate assessment. Recheck the actual instrument before relying on it; the October 9 document alone does not establish what permission will be available at a future date.
The exclusion concerns account debits
General License 135, paragraph (b), states that the license does not authorize any debit to an account on the books of a U.S. financial institution of:
- the Central Bank of the Russian Federation;
- the National Wealth Fund of the Russian Federation; or
- the Ministry of Finance.
The wording matters. It identifies a debit, an account held on a U.S. financial institution's books and the named account holders. Describing the cargo as Russian diesel does not resolve whether a proposed payment involves that excluded debit. The three account holders named in this paragraph are the subjects of this specific debit exclusion; it is not a count of every potentially relevant sanctioned party.
Firm control observation: Treasury and the processing bank should identify the accounts and institutions involved before treating the commercial activity as sufficient support for payment. Document any uncertainty about account ownership or the contemplated debit and obtain a defined assessment of that issue. GL 135's specific exclusion should be checked on its actual terms rather than rewritten as a general statement about all Russian accounts.
What this means for you
For a European fuel trader using U.S. services or payment arrangements, the useful review separates the shipment description, relevant U.S. authority, timing and account mechanics. The article does not assume that every European diesel transaction falls within U.S. jurisdiction, or that a U.S. authorization resolves another jurisdiction's rules.
Company counsel, operations and treasury can work from one dated file: the original license, the proposed transaction description, the timetable and the payment-account information. That makes unresolved questions visible before commercial commitments, rather than leaving each team to assess a different version of the transaction.
Building the program you can actually stand behind
You can request a bounded company-side U.S. sanctions review of the planned diesel transaction, its timetable and payment path. Contact Zimmermann Law to discuss that defined scope.
This post provides general information, not legal advice. Sanctions analysis is fact-specific and changes over time.
Sources: OFAC, Russia-related General License 135, “Authorizing Transactions Related to the Sale, Delivery, Offloading, and Importation of Diesel Fuel of Russian Federation Origin,” October 9, 2026, p. 1, paragraphs (a)–(b) (original `russia_gl135.pdf`); OFAC, “Issuance of Russia-related General License,” October 9, 2026. Both read October 10, 2026. GL 135 is a mandatory U.S. federal authorization instrument within its terms. The regulatory names and part numbers above are identified in the license. The eCFR part 587 retrieval encountered a publisher access challenge; the part 589 title was inspected, but the complete operative regulatory parts were not independently read for this article. Those current-regulation links are unverified as to their complete operative text; no current-regulations certification is asserted. Practical control observations are firm recommendations, not added license conditions.
This post is for general information and is not legal advice.
Attorney Advertising. Zimmermann Law PLLC · New York · +1 (917) 426-4625 · contact@zimmermann-law.com