
FAQ 1224
OFAC guidance setting the conditions for licensing a Lukoil International GmbH sale.
FAQ 1224 is OFAC guidance amended on 24 July 2026 to set the conditions any licence to complete a Lukoil International GmbH asset sale must meet: full severance, blocked proceeds, no windfall.
Last refreshed: 31 July 2026
OFAC published conditions for a Lukoil International GmbH sale licence; will one ever issue?
Timeline for FAQ 1224
Mentioned in: FAQ 1224 sets Lukoil sale conditions
European Oil MarketsBackground
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.
The guidance sets conditions not assets
OFAC amended FAQ 1224 on 24 July, publishing for the first time the conditions any future licence to effectuate a sale of Lukoil International GmbH must satisfy: complete severance from Lukoil, residual funds blocked in a US-jurisdiction account until sanctions lift, and no windfall to Lukoil through asset or share swaps.
The guidance applies only to Lukoil International GmbH and entities it owns 50% or more, issued alongside GL 131H the same day. It does not name, and has never named, ISAB or its Italian owners, a distinction that matters because coverage of the Sicilian refinery's separate sale has repeatedly conflated the two tracks.