OFAC has extended the Lukoil divestment window for the ninth time, two days before it was due to lapse

The window is open for another 28 days.

The Office of Foreign Assets Control issued Russia-related General License 131I on Thursday morning, authorising negotiations over a sale of Lukoil International GmbH through 12.01 a.m. Eastern on 19 September. The licence it replaces, 131H, was dated 24 July and was due to lapse at 12.01 a.m. on Saturday. The signature block carries a timestamp of 8.38 a.m.

What the licence permits, and the sentence that limits it

GL 131I authorises transactions otherwise prohibited by Executive Order 14024 that are ordinarily incident and necessary to negotiating and entering into contracts with Lukoil, or any of its affiliates, for the sale, disposition or transfer of Lukoil International GmbH and of any entity in which it holds 50 percent or more. Every such contract must be made expressly contingent on a separate authorisation from OFAC. The licence defines those contingent contracts broadly, and the list includes agreements in principle, binding memoranda of understanding, and bids or proposals submitted in response to public tenders. Nothing in it authorises the sale.

Paragraph (b) does the other half of the work. It authorises the maintenance or wind down of the operations, contracts and other agreements of the Lukoil International entities to the same date, and paragraph (c) allows their blocked accounts to be used, debited and credited for that purpose.

What it does not permit

Paragraph (d) runs to three lines and each one is load bearing. No property blocked under 31 CFR chapter V is unblocked, beyond the account use just described. No transaction otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations is covered where it involves a blocked person other than those named in paragraph (a). And no funds may be transferred to any person or account located in the Russian Federation.

The conditions Treasury has now published

OFAC amended two of its frequently asked questions on the same day, and 1224 is where the substance sits. It sets out what Treasury expects of any proposed transaction before it would license a sale. The deal must completely sever the ties of the subsidiary with Lukoil. Any funds owed to Lukoil must be blocked in an account subject to United States jurisdiction until sanctions are lifted. And it must not hand Lukoil a windfall, which the answer defines to include up-front value of any kind, asset swaps and share swaps included.

Two further conditions sit underneath those. OFAC says that as a condition of any future licence it expects to require a purchaser to come back for review before selling on material assets of the business. And it says it may revoke GL 131I at any time, including if Lukoil and the subsidiary do not appear to be negotiating in good faith.

Nine licences since December

Lukoil was designated on 22 October 2025. The first divestment licence, 131A, followed on 10 December, and 131B through 131I have carried the same authorisation forward since. A separate licence, 128B, was issued on 4 December 2025 to keep the retail service stations of Lukoil outside Russia trading, and its successor, 128C, runs to 29 October 2026.

Nothing in the document issued on Thursday says a buyer has been found.