What is OFAC General License 134B?: GL 134B is a Treasury Department instrument signed 17 April 2026 that authorises the sale and delivery of Russian-origin crude oil and petroleum products through 16 May 2026.Source: US Treasury
Does GL 134B cover Iran?: No. Paragraph (b) of GL 134B explicitly prohibits any transaction involving Iran, and reiterates this exclusion by reference to the Iranian Transactions and Sanctions Regulations (31 CFR part 560).Source: US Treasury
When does General License 134B expire?: GL 134B expires at 12:01 a.m. EDT on 16 May 2026, a 30-day window from its signing on 17 April 2026.Source: US Treasury
Why did OFAC renew the Russian oil licence but not the Iranian one?: On 16 April, Treasury Secretary Bessent announced that GL-U (the Iranian equivalent) would not be renewed. GL 134B's renewal on 17 April thus represents an explicit policy choice to constrain but not sever Russian oil flows, whilst severing Iranian flows entirely.Source: White House / US Treasury
What happens to Russian oil cargoes now that General License 134B has expired?: With no GL 134C issued, any in-transit Russian crude cargo loaded after 17 April falls under the base OFAC sanctions regime. Insurance and P&I cover that GL 134B extended to vessel services — crewing, bunkering, management — has also lapsed.Source: OFAC
Why did the US not renew General License 134B with a new GL 134C?: Treasury explicitly ruled out GL 134C. The non-renewal follows the same pattern as the April lapse of GL-U (Iranian crude waivers), signalling deliberate enforcement intensification rather than administrative delay.Source: US Treasury
How does the Adani $275m fine relate to the GL 134B expiry?: OFAC posted the $275m Adani Enterprises settlement for 32 Iran-LPG violations two days after GL 134B lapsed on 16 May, establishing a commodity-chain enforcement precedent for buyers who complete Russian or Iranian cargoes without waiver cover.Source: OFAC
What did General License 134B cover for shadow-fleet tankers?: GL 134B covered vessel management, crewing, bunkering, insurance, registration, and other ancillary services necessary to transport sanctioned Russian crude — a 30-day umbrella for shadow-fleet operators completing in-transit cargoes.Source: OFAC

Background

General License 134B is a Treasury Department instrument, signed 17 April 2026, that authorises ordinarily-prohibited transactions 'ordinarily incident and necessary' to the sale, delivery, and offloading of crude oil and petroleum products of Russian Federation origin loaded on vessels on or before 12:01 a.m. EDT, 17 April 2026. The licence is valid through 12:01 a.m. EDT, 16 May 2026, a 30-day window. Its scope includes vessel management, crewing, bunkering, insurance, registration, and other ancillary services required to transport sanctioned Russian crude to international buyers. Paragraph (b)(1) of the licence contains an explicit and non-negotiable carve-out: any transaction involving a person located in or organised under the laws of Iran, North Korea, Cuba, or controlled Ukrainian territories is prohibited. Paragraph (b)(2) reiterates this exclusion by reference to the Iranian Transactions and Sanctions Regulations (31 CFR part 560).

GL 134B supersedes GL 134A (dated 19 March 2026, expired 11 April 2026), continuing an iterative chain of short-term renewals that have governed Russian oil flows since the Ukraine conflict intensified. The 8-day gap between GL 134A's expiry and GL 134B's issuance created legal uncertainty; traders operated in a limbo zone where the prior licence was dead but the new one not yet signed. The pattern itself is instructive: rather than granting open-ended authorisation, OFAC issues narrow 30-day windows, forcing traders to re-negotiate their compliance posture monthly. This tactic allows the Treasury Department to signal policy shifts without invoking the formal, cumbersome process of sanctions designation or removal.

The Iran exclusion is textual, not incidental. On 16 April, Treasury Secretary Scott Bessent announced that GL-U (the equivalent licence for Iranian oil) would not be renewed, allowing it to lapse on 19 April without replacement. GL 134B's explicit mention of Iran in paragraph (b) thus stands in sharp relief: the government is not merely allowing Iranian oil sales to become illegal; it is actively designating Iran as an off-limits party whilst simultaneously renewing cover for Russian flows. This asymmetry reflects an administration strategy: Russia's oil revenues are constrained but still partially accessible to US-allied traders; Iran's are severed entirely. The timing: renewal on 17 April, Iranian lapse on 19 April. This compresses this pivot into 48 hours, affecting secondary-sanction exposure for approximately 325 tankers with roughly $31.5 billion in Iranian crude mid-transit.

GL 134B's expiry at 12:01 ET on 16 May 2026 with no successor instrument is the lead regulatory anchor of European oil markets Update #1. Treasury explicitly ruled out GL 134C, ending the iterative monthly waiver chain that had governed Russian crude in-transit flows since March 2026.

For European buyers, the practical consequence is immediate: completion of any in-transit Russian crude cargo loaded after 17 April now operates under the base sanctions regime rather than waiver cover. The insurance and P&I umbrella that GL 134B extended to vessel management, crewing, bunkering, and salvage services for shadow-fleet operators expired with the licence. International Group P&I clubs have no authority to continue coverage for transactions that fall back under primary OFAC jurisdiction. Two days after the lapse, OFAC published the $275 million Adani Enterprises settlement for 32 Iran-LPG violations — a commodity-chain enforcement precedent that signals active prosecution rather than further tolerance for in-transit completion arguments.

Source Material

General License 134B — OFAC Recent Actions OFAC Cuba sanctions: General Licences

How the World Sees Them

Non-renewal signals a shift toward enforcement intensification rather than managed waivers; the GL 134B exit follows the same pattern as GL-U's April lapse, framing both as deliberate policy rather than oversight.

India

The Adani $275m settlement creates a direct precedent for Asian buyers who completed Iranian cargoes under lapsed waivers — and raises the compliance stakes for any Russian-cargo completion under GL 134B's successor vacuum.

Russia

Moscow loses the partial US-allied legitimacy that 30-day waivers provided. Shadow-fleet operators face increased insurance and port-access friction without the vessel-services umbrella.

European traders

Completion of any in-transit Russian cargo now runs under base sanctions. Insurance cover expired with the licence; P&I clubs cannot extend protection to unwaivered transactions.