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General License No. 131I Authorizing Transactions for Lukoil International GmbH Sale and Maintenance

General License No. 131I authorizes transactions prohibited by Executive Order 14024 that are ordinarily incident and necessary to negotiate or enter contingent contracts for the sale of Lukoil International GmbH (LIG) and related entities, provided performance is contingent on separate Office of Foreign Assets Control authorization. The license also permits transactions for the maintenance or wind-down of LIG Entities' operations and allows the use of blocked accounts for these purposes through 12:01 a.m. eastern daylight time on September 19, 2026. It explicitly prohibits unblocking property except as authorized, transactions involving other blocked persons under the Russian Harmful Foreign Activities Sanctions Regulations, and fund transfers to the Russian Federation. This license replaces and supersedes General License No. 131H effective August 20, 2026.

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DEPARTMENT OF THE TREASURY WASHINGTON, D.C. OFFICE OF FOREIGN ASSETS CONTROL Russian Harmful Foreign Activities Sanctions Regulations 31 CFR part 587 GENERAL LICENSE NO. 131I Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities (a) Except as provided in paragraph (d) of this general license, all transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the negotiation of and entry into contracts with Public Joint-Stock Company Oil Company Lukoil or any of its affiliates for the sale, disposition, or transfer of Lukoil International GmbH (“LIG”) or any entity in which LIG owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively, “LIG Entities”) are authorized through 12:01 a.m. eastern daylight time, September 19, 2026, provided that the performance of any such contract is made expressly contingent upon the receipt of separate authorization from the Office of Foreign Assets Control (“contingent contracts”). Note to Paragraph (a). For purposes of this general license, the term “contingent contracts” includes executory contracts, executory pro forma invoices, agreements in principle, executory offers capable of acceptance such as bids or proposals in response to public tenders, binding memoranda of understanding, or any other similar agreement.

(b) Except as provided in paragraph (d) of this general license, all transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements of LIG Entities are authorized through 12:01 a.m. eastern daylight time, September 19, 2026. (c) All blocked accounts of LIG Entities may be used, debited, or credited for the transactions authorized in paragraph (b). (d) This general license does not authorize: (1) The unblocking of any property blocked pursuant to any part of 31 CFR chapter V, except as authorized in paragraph (c); (2) Any transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including transactions involving any person blocked pursuant to the RuHSR, other than blocked persons described in paragraph (a) of this general license, unless separately authorized; or

2 (3) The transfer of funds to any person or account located in the Russian Federation. (e) Effective August 20, 2026, General License No. 131H, dated July 24, 2026, is replaced and superseded in its entirety by this General License No. 131I.


Bradley T. Smith Director Office of Foreign Assets Control Dated: August 20, 2026

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