General License 134B

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 is the lead regulatory anchor of European oil markets Update #1. GL 134B was superseded by General License 134C, which extended in-transit completion cover to 17 June 2026, continuing the iterative monthly waiver chain.

For European buyers, the practical consequence of each monthly expiry is the same: any in-transit Russian crude cargo loaded after the cut-off date falls back under the base sanctions regime unless a successor licence is in effect. 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 until GL 134C was issued. International Group P&I clubs have no authority to continue coverage for transactions that fall back under primary OFAC jurisdiction. Two days after the GL 134B 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 tolerance for in-transit completion arguments.