Regulatory Alerts2026-03-02 | 2026-04087Publication of Russian Harmful Foreign Activities Sanctions Regulations General Licenses 124A, 126, 127, 128, 130, 131, and 131A
The Department of the Treasury’s Office of Foreign Assets Control published several general licenses under the Russian Harmful Foreign Activities Sanctions Regulations to authorize specific transactions involving Russian energy entities. These licenses permit activities related to the wind-down of operations, divestment of debt or equity, and maintenance of retail stations for Rosneft and Lukoil, as well as transactions involving Lukoil entities in Bulgaria and the sale of Lukoil International GmbH. The document notes that General Licenses 126, 127, 128, 131, and 131A have expired, while General License 130 remains valid through April 2026.
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