The US Treasury's Office of Foreign Assets Control (OFAC), the body that writes and enforces American sanctions, issued General Licence 131H on 24 July1. A general licence is a standing authorisation that permits a class of transaction which sanctions would otherwise prohibit. This one authorises negotiating and entering into contingent contracts for the sale of Lukoil International GmbH and related maintenance activities, running to 22 August. It is the eighth consecutive monthly rollover of that same window, and it covers negotiation only: closing any sale still needs a separate, deal-specific OFAC licence.
It is the principal Russia-related action OFAC took in the window, and it is not the one the market was watching. The crude-oil waiver remains unrenewed, having already lapsed without a successor when this briefing last checked the register. A general licence that expires and is not replaced does the work of a new sanction while requiring no announcement, no coalition and no vote, since the prohibition it was suspending simply resumes.
Sanctions agencies are read as much by what they choose to touch as by what they issue. OFAC has continued rolling over the routine Lukoil divestment window on schedule while leaving the oil file untouched, and an agency that is administratively active but substantively still is telling readers that inaction on crude is a position rather than an oversight.
