FAQ 1224

FAQ 1224 is Office of Foreign Assets Control guidance interpreting Russia-related sanctions. It sets out how OFAC will treat any proposed sale of Lukoil International GmbH, the Austrian-registered Lukoil subsidiary that has been under a rolling monthly negotiation licence since April 2026.

On 24 July, alongside General Licence 131H, OFAC amended the guidance to publish the conditions any future licence to complete such a sale would have to satisfy: complete severance from Lukoil, residual funds blocked in a US-jurisdiction account until sanctions lift, and no windfall through asset or share swaps. The guidance applies only to Lukoil International GmbH and entities it owns 50% or more; it says nothing about ISAB, Priolo Gargallo or any other asset outside that perimeter.

By publishing a fixed standard rather than leaving the terms to case-by-case discretion, OFAC gave prospective buyers of Lukoil International GmbH's remaining assets, Neftochim Burgas in Bulgaria and Petrotel Ploiesti in Romania, a template to negotiate against, though it does not itself resolve the timeline for when, or whether, a transaction licence follows.