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FAQ 1224
LegislationUS

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

Key Question

OFAC published conditions for a Lukoil International GmbH sale licence; will one ever issue?

Timeline for FAQ 1224

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Background

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.

Key Issues
Sale conditions

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.

Common Questions
What conditions does OFAC require to license a Lukoil International GmbH sale?
Complete severance of the sold business from Lukoil, residual funds blocked in a US-jurisdiction account until sanctions lift, and no windfall to Lukoil through asset or share swaps.Source: OFAC
What entities does FAQ 1224's Lukoil sale guidance actually cover?
Only Lukoil International GmbH and entities it owns 50% or more. It does not name ISAB, Priolo Gargallo or Italy: ISAB Left the Lukoil perimeter when Litasco sold it to GOI Energy in May 2023.Source: OFAC
When was FAQ 1224 last amended?
OFAC amended FAQ 1224 on 24 July 2026, alongside general licence 131H.Source: OFAC