OFAC issues GL 131E for Lukoil contract negotiations
→Sanctions teams may negotiate defined Lukoil sale contracts under GL 131E only
Change
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
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Source
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