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This post has been updated to reflect OFAC’s issuance of amended General License 134A on March 19, 2026, which supersedes and replaces General License 134.
Overview
On March 19, 2026, OFAC issued the amended General License 134A (“GL 134A”), superseding the previous General License 134, which created a narrow authorization for the sale, delivery, and offloading of Russian‑origin crude oil and petroleum products that were already loaded onto vessels on or before 12:01 a.m. EDT, March 12, 2026. This authorization continues to remain in effect until 12:01 a.m. EDT, April 11, 2026.
GL 134A is seemingly designed to prevent immediate disruptions in the global oil supply chain by allowing the completion of transactions involving Russian‑origin cargoes that were already in transit prior to March 12. OFAC’s issuance comes during a period of heightened global energy volatility, with reports noting significant price pressure following intensified conflict involving Iran. Following news reports, those events have contributed to sharply rising oil prices and concerns about supply constraints. See What to Know About the Rising Price of Oil and Its Effects on Airline Ticket Prices - The New York Times.
Scope of Authorized Activities
GL 134A authorizes all transactions ordinarily incident and necessary to the sale, delivery, or offloading of qualifying Russian‑origin oil and petroleum products. This includes a wide scope of maritime operational activity that is essential to safely moving oil shipments through global ports and waterways. Following the license terms, authorized activities extend to safe docking and anchoring, the provision of services required for the health and safety of the crew, emergency repairs, and any environmental mitigation or protective operations related to the vessel.
The license further encompasses vessel management and commercial maritime services such as crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage. In Note 1 within the license, OFAC expressly states that these activities are authorized even when the relevant vessels themselves are considered “blocked” under one or more of the sanctions authorities referenced in the license. Russian‑origin crude oil and petroleum products covered by the license also include those produced by entities sanctioned under the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587) or Ukraine-/Russia-Related Sanctions Regulations (31 CFR part 589).
Taken together, these provisions create a narrowly focused but functional pathway for energy traders, refiners, maritime operators, and insurers to complete transactions that were already in progress before March 12. We note that the license does not authorize new spot purchases or fresh commercial engagement with Russian producers; rather, it is carefully tailored to allow for the orderly liquidation of cargoes already en route.
Limitations and Prohibitions
While generally broad in the scope of authorized activities permitted, GL 134A’s substantive scope is strictly limited. Following the license text, OFAC has clarified that the license does not authorize any transactions beyond those required to complete the sale, delivery, or offloading of the specifically described Russian‑origin cargoes.
A key amendment in GL 134A is the expanded paragraph (b)(1), which now expressly prohibits any transaction involving persons located in, or organized under the laws of, Iran, the Democratic People’s Republic of Korea, Cuba, the Covered Regions of Ukraine, or Crimea, as well as any entity owned or controlled by, or in a joint venture with, such persons. This marks a material enlargement of the exclusions in GL 134, significantly broadening the categories of jurisdictions and counterparties that fall outside the authorization.
A particularly important restriction that was maintained, though now situated within a broadened set of prohibitions, is the long‑standing bar on engaging in any transaction involving Iran, the Government of Iran, or Iranian‑origin goods or services, except to the limited extent such dealings fall within the narrow parameters of paragraph (a) of GL 134A. This reflects OFAC’s consistent approach to Iran‑related sanctions and underscores that the temporary wind‑down for Russian cargoes should not be construed as relaxing restrictions under other U.S. sanctions programs.
As with its predecessor, GL 134A does not unblock any property or authorize dealings with non‑Russian sanctioned actors. It continues to permit activity involving vessels that are themselves sanctioned or otherwise considered “blocked,” but only to the extent such activity falls squarely within the license’s limited wind‑down authorization.
Key Takeaways
GL 134A should be viewed within the broader geopolitical landscape. Reports indicate that the global oil market is experiencing sharp pricing pressures following intensified conflict involving Iran, including military strikes that contributed to rising concerns about regional supply disruptions. These developments compound fears around the security of maritime chokepoints, insurance availability, and the immediate availability of alternative barrels. See Oil prices surge as Iran escalates tanker attacks, shares fall - Reuters. From our perspective, GL 134A is a targeted limited measure intended to stabilize near‑term market conditions by ensuring that oil already loaded onto vessels could continue moving rather than being immobilized under tightening sanctions and increased tensions surrounding Iran.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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