OFAC Extends Lukoil Negotiation Window to 28 June 2026 Under GL 131F

What happened

On 28 May 2026, the US Office of Foreign Assets Control (OFAC) issued Russia-related General License 131F, authorising a defined set of activities related to the potential sale of Lukoil International GmbH (LIG). The licence permits negotiations, financial and legal due diligence, operational due diligence, engagement of outside counsel and advisors, and wind-down of LIG operations. It expires on 28 June 2026.

GL 131F does not authorise the actual sale, disposition, or transfer of any LIG entity or asset. OFAC states explicitly that any contract entered into under the licence must be expressly contingent on receipt of a separate OFAC authorisation before the transaction closes. OFAC published amended Russia-related FAQs alongside the licence on the same date.

GL 131F is the latest in a series of negotiation-licence extensions covering Lukoil’s overseas assets. An earlier licence, GL 131D, had extended the negotiation window through 1 May 2026. The repeated renewals, running since November 2025, reflect the prolonged and unresolved nature of the divestiture process.

Why it matters

The pattern of serial short-window renewals is worth reading carefully. Each extension is a narrow, time-boxed, conditional permission. None of them constitutes a signal that the underlying transaction has been approved or that OFAC policy on Lukoil assets has relaxed. The distinction between negotiation authority and sale authority is the operative legal line, and it is one practitioners at counterparty banks and advisory firms have tripped over in past Russia sanctions cycles.

The amended FAQs published alongside GL 131F are not cosmetic. OFAC FAQ amendments frequently clarify scope, permissible parties, or specific activities that were generating industry queries. Sanctions officers should treat the FAQ update as part of the primary document set, not a footnote. The FAQs may narrow or expand how the licence terms are read in practice.

It is worth noting, as an analytical observation rather than a confirmed regulatory signal, that the same OFAC update cycle that extended the Lukoil negotiation runway also included tightening actions on Iran. Sanctions programs move in different directions within the same week. Treating a general licence in one program as a barometer for regulatory sentiment across programs is an error that compliance teams should consciously avoid.

Practitioner angle

Read GL 131F and the amended Russia-related FAQs in full before processing or facilitating any activity connected to LIG. The licence text carries precise scope language; the FAQ amendments may resolve ambiguities that the licence itself leaves open.

Confirm two conditions before any transaction proceeds. First, the activity falls within the authorised categories: negotiations, due diligence, advisory engagement, or operational wind-down. Second, any contract is expressly contingent on receipt of a further, separate OFAC authorisation covering the actual transfer or disposition. If either condition is not satisfied in writing, the transaction is not covered.

Do not treat negotiation authority as sale authority. Document the contingent-authorisation language in your transaction records at the point of onboarding the engagement, not retrospectively. If your institution is advising, financing, or providing services to any party in this process, that documentation is your primary defence in the event of a later query.

Diarise 28 June 2026 as a hard deadline. If the transaction has not closed and a further extension is not issued before that date, all activities authorised under GL 131F must cease. Check OFAC’s recent actions page in the days approaching expiry; extensions in this series have been issued close to the prior deadline.

The single most important step: read the amended FAQs now, not after a client or counterparty raises a question.