Sanctions Became Law. The Lukoil Licence Moved Again.

On 18 September the President signed a bill putting sanctions on Russia into statute. The same day, the Treasury bureau that runs those sanctions replaced the licence that lets buyers negotiate for Lukoil's refineries and filling stations outside Russia. Set the new licence beside the old one and the paragraphs match. The date is what changed.

Two documents left Washington on Friday, 18 September 2026. Both concern the same Russian oil company, and they run in opposite directions.

The first was a bill signing. The White House recorded that the President signed H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026. The statement announcing it runs to a single sentence, which says the law “authorizes and expands statutory sanctions, tariffs, and prohibitions on Russia and extends existing sanctions on Iran.” Confirmed

The second was a licence. The Office of Foreign Assets Control, the Treasury bureau that administers economic sanctions, issued Russia-related General License 131J. It replaced General License 131I, the licence this publication reported on 21 August, which had been authorised to run only to 12:01 a.m. eastern daylight time on 19 September 2026. The new document carries a new expiry, 12:01 a.m. eastern daylight time on 22 October 2026. Confirmed

The Text Did Not Change. The Date Did.

Set General License 131I and General License 131J side by side and the operative paragraphs are the same. Both authorise transactions “ordinarily incident and necessary to the negotiation of and entry into contracts” with Lukoil for the sale, disposition or transfer of Lukoil International GmbH, the Vienna holding company through which Lukoil owns refineries in Bulgaria and Romania, a stake in a Dutch refinery and roughly 2,500 retail fuel stations across 19 countries. Both reach any entity in which that holding company owns 50 per cent or more. Both require that any contract signed under them be made expressly contingent on a separate OFAC authorisation granted later. Both authorise maintenance and wind-down of those entities' operations. Both decline to authorise the unblocking of property, and both decline to authorise the transfer of funds to any person or account located in the Russian Federation. Both carry the signature of Bradley T. Smith, Director of OFAC. Confirmed

Confirmed OFAC General Licenses 131I and 131J, both read in full on 19 September 2026. The two documents differ in the expiry date, which appears twice in each, and in the closing sentence naming the licence superseded.

The sequence began in November 2025 with General License 131. OFAC marks each step by supersession rather than by a published count, so the series is read by its letters rather than by an ordinal. The public answer OFAC attaches to the licence was first released on 19 November 2025. Confirmed

What OFAC Asks For Before a Lukoil Sale

OFAC amended two of its published answers the same day it issued the new licence. The first, numbered 1224 and updated 18 September 2026, sets out what the bureau would look for in any eventual sale. Its conditions are unchanged from the version this publication read in August. OFAC states that it “expects that, at a minimum, the proposed transaction must: completely sever LIG's ties with Lukoil; block any funds owed to Lukoil until sanctions are lifted by placing them in an account subject to U.S. jurisdiction; and not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps.” It adds that a buyer would be required to seek OFAC review before selling on any material asset of the holding company. Confirmed

The same answer records what the licence covers in practice: “negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors.” It states plainly that the licence “expires on October 22, 2026,” and that OFAC “may revoke GL 131J at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.” Confirmed

The Designation the Licence Sits On Top Of

On 22 October 2025 Treasury designated Rosneft and Lukoil under Executive Order 14024, “for operating or having operated in the energy sector of the Russian Federation economy,” and named 34 Russian subsidiaries in an annex. The release states that “all entities owned 50 percent or more, directly or indirectly, by Rosneft and Lukoil are blocked pursuant to E.O. 14024, even if not designated by OFAC.” That sentence is what reached the Vienna holding company and the European refineries under it. Confirmed

Scott Bessent, Secretary of the Treasury, quoted in the designation release of 22 October 2025. Confirmed

The designation was made on 22 October 2025. The licence issued on 18 September 2026 runs to 22 October 2026.

A Buyer Has Been Waiting Since January

Lukoil said on 29 January 2026 that it had signed a non-exclusive agreement with the United States private equity firm Carlyle Group for the sale of the holding company, excluding its Kazakhstan assets, conditioned on OFAC approval, and that it continued negotiating with other parties. An earlier agreement with the commodities trader Gunvor Group, reached in October 2025, was rejected. Confirmed as reported

By March 2026 Lukoil had written the holding company off its own books entirely, an impairment of 1.66 trillion rubles, and told shareholders the outcome rested on OFAC's decision. Market estimates carried alongside that filing put the international portfolio at roughly $22 billion, a figure neither OFAC nor Lukoil has confirmed. Confirmed as reported

Where This Has a Measured Edge

The assets in question sit in Europe. Bulgaria and Romania host the holding company's largest refineries, and those two countries posted the European Union's two highest year-on-year fuel-price increases in June 2026.

Measured Eurostat, “Evolution of fuel prices in June 2026,” published 22 July 2026. The same release shows diesel and petrol both easing month on month across the EU that June, down 6.4 per cent and 4.2 per cent from May.

This publication reported in August that no source it located isolates how much of that inflation traces to the ownership question as against the wider 2026 movement in crude prices. The same Eurostat release shows Lithuania, Finland and Luxembourg running comparably high fuel inflation the same month, and none of the three hosts a Lukoil refinery. Measured

What the Record Shows, and What It Does Not Fix

A statute now sits under the Russia sanctions programme. A licence issued under that programme the same day holds open, for another five weeks, the authority to negotiate the sale of one designated company's foreign business. Both are on the public record, dated, and signed. What is on the record is the authority to negotiate and the date it ends, not a completed sale: no OFAC document reviewed for this piece records that any buyer has closed a purchase of the holding company.

Corrections

Two corrections to this publication's article of 21 August 2026, Treasury Extends Lukoil's Sale Deadline to September 19, both found while reading the primary documents for this piece.

First, a misattributed quotation. That article reported that the Secretary of the Treasury said the department would “continue to advocate for a peaceful resolution to the war.” The sentence appears in the body of Treasury's release of 22 October 2025, not inside the Secretary's quoted remarks, and it reads “The United States will continue to advocate for a peaceful resolution to the war.” The Secretary's quoted remarks that day are reproduced above.

Second, an expiry stated imprecisely. That article reported that General License 131I “extends through September 19, 2026.” The licence authorises transactions through 12:01 a.m. eastern daylight time on 19 September 2026, which is one minute after midnight at the start of that day rather than the end of it. The last full day of authorised negotiation under 131I was 18 September, the day OFAC issued its replacement.

Nothing published here is investment, legal or security advice.