General License GL 131F — 2026 Guide

GL 131F permits U.S. persons and entities subject to U.S. jurisdiction to engage in three specific categories of activity with Lukoil International GmbH and its majority-owned subsidiaries:

This license replaced GL 131D, which expired May 1, 2026. OFAC extended the deadline twice in spring 2026 (first to May 30, then to June 28) and according to OFAC FAQ 1224, the extension was granted “to provide additional time for the orderly divestment of these entities while protecting the interests of non-sanctioned counterparties.”

Why does GL 131F matter? Without it, any transaction involving LIG—even preliminary negotiations—would constitute a prohibited dealing with a blocked person under 31 C.F.R. § 589.201, triggering strict liability for violations. There is no intent requirement. A good-faith error still exposes companies to $330,000 per violation civil penalties, plus potential criminal prosecution for willful conduct. The license creates a narrow compliance corridor, but only if you stay precisely within it.

Lukoil International GmbH is not an upstream oil producer—it operates downstream fuel distribution networks across Austria, Belgium, Germany, Hungary, Italy, Poland, Romania, and Slovakia. As of January 2026, LIG entities controlled approximately 4,800 retail fuel stations in these markets, representing an estimated 12% of Central European motor fuel retail capacity. Sanctions on LIG created immediate supply-chain disruption risks for European consumers and businesses. OFAC acknowledged this in extending the license, but do not mistake that acknowledgment for sympathy. The agency extended the deadline to create an orderly market exit, not to subsidize continued Russian control of European fuel supply.

GL 131F authorizes the following energy-sector activities:

Maintenance and Safety Operations. Ongoing operation of fuel storage facilities, pipelines, and retail stations necessary to prevent environmental hazards or ensure worker safety. This includes payments for utilities, insurance premiums, and regulatory compliance costs directly tied to facility operations.

Inventory Management. Sale or transfer of existing petroleum product inventories held by LIG entities, provided the transaction is part of a documented divestment plan and payment does not flow to accounts in the Russian Federation.

Contract Novation and Assignment. Transfer of existing supply contracts from LIG entities to non-sanctioned buyers, including negotiation of assignment fees, break clauses, and transition service agreements. OFAC FAQ 1225 states: “non-U.S. persons conducting transactions consistent with the terms of GL 131F generally do not risk secondary sanctions exposure.” This is crucial protection for European buyers who might otherwise face reputational or banking pressure from U.S. financial institutions.

Hedging and Derivatives Close-Out. Termination of commodity hedges, futures contracts, and other derivative positions tied to LIG energy trading activities, provided close-out payments are placed in blocked accounts pending OFAC approval.

Third-Party Due Diligence. Engagement of auditors, environmental consultants, legal advisors, and financial advisors to assess LIG asset valuations, liabilities, and regulatory compliance status in preparation for divestment.

What GL 131F does not authorize:

Regulatory overlap compounds compliance complexity. The U.S. Department of Energy’s export control rules (10 C.F.R. Part 810) apply to any transfer of nuclear technology or technical data related to LIG’s Central European operations. The Bureau of Industry and Security (BIS) Export Administration Regulations (15 C.F.R. Part 730) govern shipment of U.S.-origin equipment or software used in LIG facilities. Companies relying on GL 131F must independently verify compliance with these parallel regimes—OFAC authorization does not create a safe harbor for export control violations.

GL 131F authorizes “transactions ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements involving Lukoil International GmbH and its majority-owned subsidiaries” (OFAC FAQ 1225). That phrase—borrowed from OFAC’s standard wind-down template—sounds flexible. It isn’t. The compliance burden falls entirely on you.

Based on OFAC’s historical interpretation in prior Russia and Iran licenses, these categories are protected:

Pre-Existing Contract Performance: You can fulfill payment obligations under contracts signed before November 21, 2024 (LIG’s designation date). This includes delivering goods or services already ordered, paying invoices with terms predating designation, and handling warranty or maintenance claims from old equipment sales. The key cutoff is the signature date, not the payment date.

Administrative and Operational Costs: Salaries for LIG employees, lease or rent for ongoing facilities, utilities and insurance for operations, and professional fees for accountants, auditors, and lawyers supporting wind-down work. These are boring expenses—and therefore safe bets for GL 131F protection.

Due Diligence and Transaction Advisory: Financial advisors preparing asset valuations, environmental consultants assessing facility liability, legal counsel drafting transaction documents and navigating regulatory approvals, and IT consultants evaluating systems. If you’re selling LIG assets, invest heavily in documentation. OFAC will demand proof that every advisory fee served the wind-down.

Contingent Contract Execution: You can sign sale or transfer agreements explicitly conditioned on future OFAC authorization, negotiate price and payment terms, and establish escrow accounts pending OFAC approval. One mandatory rule: escrow funds must sit at non-Russian financial institutions. If the escrow agent is based in Moscow, the entire arrangement is prohibited.

Regulatory Compliance and Reporting: Filing required reports with host-country regulators, responding to government inquiries or audits, and maintaining EU or member-state corporate governance structures. These are defensive compliance measures—generally safe.

GL 131F explicitly does not authorize:

“Majority-owned subsidiaries”—that’s a trap. OFAC doesn’t publish a definitive list. You must verify ownership using corporate registry data from Austria, Germany, or other host jurisdictions to confirm 50%-or-more LIG ownership. If you guess wrong, the transaction is prohibited regardless of your good intent.

GL 131F doesn’t require you to file periodic reports. But don’t mistake that for a free pass. OFAC’s general enforcement framework creates implicit record-keeping obligations—and those obligations bite hard.

Documentation Standards: Under 31 C.F.R. § 501.601, keep “a full and accurate record of each transaction” for five years from the transaction date. For GL 131F, this means:

OFAC can demand these documents at any time. If you can’t produce them during an audit or investigation, the presumption flips: your transaction violated sanctions unless you prove otherwise. Missing records are enough to sink your defense.

No Pre-Transaction Approval Required: Unlike specific licenses, you don’t need OFAC’s green light before acting. But if you’re genuinely uncertain whether a transaction falls within GL 131F scope, you can request an advisory opinion. OFAC takes 30 to 90 days to respond. If you can’t wait and proceed on your own analysis, document your reasoning. You’ll need that paper trail if OFAC questions the transaction later.

Payment Routing and Blocked Accounts: OFAC FAQ 1225 is crystal clear: “no payments may be transferred to any person or account located in the Russian Federation.” This forces you to screen every payment. In correspondent banking chains, pull Swift field 56 (intermediary bank) and field 57 (account-with institution) data. Verify no payment leg touches a Russian institution.

If a GL 131F payment accidentally routes through Russia, the receiving U.S. or European bank blocks it and files a blocked property report with OFAC within 10 business days (31 C.F.R. § 501.603). You then apply for a specific license to free the funds—but specific licenses currently take 120+ days. Expect your money trapped for months.

Audit and Penalty Risk: OFAC conducts random audits of general license compliance, particularly for high-value energy sector transactions. Civil penalties for negligent violations range from $330,000 to $22 million per violation, depending on the transaction value and the violator’s compliance program quality. For willful violations, criminal penalties under 18 U.S.C. § 1001 include fines up to $1 million and imprisonment up to 20 years.

A February 2025 case shows what can go wrong. A European energy trading firm paid $8.4 million to settle allegations that it made 14 payments to LIG entities after designation but before GL 131A took effect. The company’s defense—that it hadn’t seen the SDN List update—didn’t work. OFAC held that companies must monitor press releases in real time, not wait for official list publications. Miss that window, and ignorance won’t protect you.

Effective GL 131F compliance requires integration of sanctions controls into commercial, legal, and finance functions. Here’s what to build:

Internal Policy Development: A written GL 131F compliance policy should define authorized transaction categories, specify approval workflows, identify prohibited payment routes, and establish documentation standards. Include a decision tree: if a proposed transaction falls outside the defined categories, it escalates to legal counsel for specific license application or advisory opinion review.

Training Protocols: Role-specific training for:

Document attendance and competency assessments—OFAC treats training quality as a penalty mitigator if violations occur.

Technology Integration: ERP systems, payment platforms, and contract management tools should:

Specialized legal compliance platforms integrate OFAC screening APIs directly into invoice approval workflows, reducing manual review burden.

Third-Party Risk Management: For transactions involving LIG subsidiaries, commission:

Standard practice: order third-party reports for any transaction exceeding $500,000 or involving multi-party payment chains.

Contingency Planning for Expiration: GL 131F expires June 28, 2026. Here’s what to do now:

OFAC’s specific license applications take 90-120 days on average. File after April 1, 2026, and you likely won’t get approval before expiration. Companies facing this risk should file immediately and document good-faith compliance efforts—that matters for penalty mitigation if something goes wrong.