OFAC has issued an amended version of Russia General License 131D, which specifically authorizes transactions related to the negotiation and entry into contingent contracts for the sale of Lukoil International GmbH and related maintenance activities. The license was amended to clarify or expand the scope of permitted dealings with the Russian energy company. Additionally, OFAC revised FAQ 1224 and FAQ 1225 to address compliance questions related to this Russia sanctions measure.

Companies engaged in any transactions involving Lukoil International GmbH or other Russian energy sector entities should review the amended General License 131D to determine whether their activities fall within the newly authorized scope. Compliance teams should consult the revised FAQs for additional interpretive guidance. Any entity relying on this general license should ensure they meet all conditions specified therein and maintain appropriate documentation.