Skip to content
You can now search across every topic, entity and event.What's new
GL-131E
LegislationUS

GL-131E

First OFAC Lukoil-sale negotiation licence, issued 29 April 2026; superseded by GL 131F.

Last refreshed: 27 July 2026 · Appears in 2 active topics

Key Question

What exactly is being designated in the OFAC shadow-banking action, and who is it targeting?

Timeline for GL-131E

View full timeline →
Follow Iran Conflict 2026 →Follow European Oil Markets →

Background

General License 131E (GL-131E) is the first instrument in OFAC's monthly Lukoil International GmbH (LIG) asset-sale negotiation series, issued 29 April 2026. It authorised negotiation only, not completion, of any sale of LIG's non-Russian refining assets. It was a Russia sanctions instrument with no Iran component: 29 April was the first Russia-only OFAC day of the Iran war, breaking a pattern of weekly Iran-linked OFAC action, and the break coincided with the day Chuck Schumer scheduled the War Powers Resolution vote. It did not cover the ISAB Priolo refinery in Sicily, which Lukoil's trading Arm Litasco had already sold to GOI Energy in May 2023.

GL-131E was issued one day after OFAC's 28 April sb0477 action, which designated 35 entities and individuals across Iran's shadow banking network under Executive Orders 13902 and 13224. The two instruments are separate programmes issued in the same 24-hour window, not parts of a single action: sb0477 is an Iran-sanctions designation, GL-131E a Russia-sanctions licence. OFAC superseded GL-131E with General License 131F on 28 May 2026, opening the monthly rollover pattern that continued through GL 131G (25 June) and GL 131H (25 July).

GL-131E set the template the whole GL 131 series has followed since: a negotiation-only authorisation renewed roughly monthly, with no transaction licence ever issued to close a sale, and buyer conditions (formalised as FAQ 1224 from GL 131F Onward) requiring full severance from Lukoil and funds parked in a US-jurisdiction blocked account. Its issuance date is the fixed reference point analysts use to count how many consecutive rollovers the series has run, eight by GL 131H.

Common Questions
What is OFAC sb0477 and what does it target?
OFAC sb0477 'Economic Fury Targets Iran Shadow Banking Facilitators' was issued 28 April 2026, designating 35 entities and individuals involved in Iran's shadow banking architecture under Executive Orders 13902 and 13224.Source: OFAC
How does Iran move money to avoid US sanctions?
Iran uses a network of front companies, informal money changers, and Shell entities across multiple jurisdictions to route payments outside dollar-clearing systems. OFAC sb0477 targeted 35 such facilitators in its 28 April 2026 action.Source: OFAC
What is GL-131E and what does it authorise?
GL-131E is an OFAC general licence issued 29 April 2026 authorising negotiations to sell Lukoil International GmbH, a Russian entity. It was the only OFAC action on 29 April, making it the first Russia-only day of the Iran war, breaking a six-week weekly Iran sanctions cadence.Source: OFAC
Why was 29 April 2026 significant for Iran sanctions?
On 29 April 2026 OFAC issued only GL-131E, a Russia-related licence for Lukoil International GmbH, with no Iran action. It was the first Russia-only day of the war, breaking the weekly Iran OFAC cadence that had run since February 2026.Source: OFAC
What is General License 131E?
GL-131E was OFAC's first licence, issued 29 April 2026, authorising negotiation only of a sale of Lukoil International GmbH's non-Russian refining assets; it was superseded by GL 131F on 28 May 2026.Source: event
Does General License 131E cover Iran sanctions?
No. GL-131E is a Russia sanctions instrument with no Iran component, issued the day the US Senate scheduled its Iran War Powers Resolution vote.
What licence did OFAC replace GL-131E with?
OFAC superseded GL-131E with General License 131F on 28 May 2026, continuing the monthly Lukoil International GmbH sale-negotiation series that reached GL 131H by 25 July 2026.Source: event
Why does the GL 131 licence series keep rolling over monthly?
OFAC renews the Lukoil International GmbH negotiation window in one-month increments because no buyer has been confirmed; a completed sale would instead need a separate transaction licence.