21MAY

US Oil Sanctions Waiver Expires 11 April Amid Confusion

2 min read

09:55UTC

OFAC's GL 134A expires 11 April; at $121 per barrel, any extension would hand Russia far more revenue than when the waiver was issued at $73, while simultaneous vessel desanctioning created contradictory signals.

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Key takeaway

GL 134A expiry on 11 April is the binary choice: extension at $121/barrel or lapse compounding Russia's crisis.

OFAC issued General License 134 on 12 March, covering the roughly 124 million barrels of Russian crude at sea , amended it to GL 134A on 19 March, and faces a binary decision on its 11 April expiry. At $73 per barrel when issued, the waiver was defensible as market stabilisation. At $121, the same licence authorises far greater per-barrel income than its design contemplated.

OFAC added Iran, North Korea, and Cuba exclusions to GL 134A one week after the original licence, a rapid amendment suggesting Treasury received evidence that cargoes were being redirected toward sanctioned parties. On 31 March, OFAC separately removed sanctions on three Russian cargo vessels: Fesco Magadan, Fesco Moneron, and SV Nikolay.

The contradictory pattern, tightening the licence's terms while reducing pressure on named Russian vessels, is consistent with an administration managing competing objectives across the Iran war and Ukraine simultaneously. The Atlantic Council warned that extension at current prices "risks sustaining Russia's war effort."

Deep Analysis

In plain English

The US government gave Russia a special oil sales exemption that expires on 11 April. When it was issued, oil prices were around $73 per barrel. Now that the Iran war has pushed prices to $121, extending the same exemption would hand Russia much more money than originally intended. At the same time, the US removed sanctions on three Russian ships while tightening the exemption's rules — sending confusing signals about American policy toward Russia.

What could happen next?

Risk
GL 134A extension at $121/barrel would constitute the largest single US-authorised revenue transfer to Russia since sanctions began.

Source Landscape

This story draws on neutral-leaning sources

At $73/barrel (waiver issuance price), each barrel of Russian crude under GL 134A generated approximately $29 above the $44.10 cap. At $121/barrel, the same barrel generates $76.90 above cap — a 2.6x increase in per-barrel sanction circumvention value.

Consensus view: Atlantic Council and external sanctions analysts assess extension at current Urals prices would directly fund Russian war prosecution at levels the waiver was never designed to permit.

Counter-view: Treasury may extend on Iran war market stabilisation grounds — the same justification that applied at $73/barrel, though far less defensible at $121.

Key tension: Whether Treasury's Iran war stabilisation objective outweighs the revenue-to-Russia impact of extension at current oil prices.

Sources:Mayer Brown

Mentions:Moscow →Ukraine →Iran →Urals →North Korea →Russia →OFAC →Atlantic Council →

First Reported In

Update #11 · Russia Sells Less Oil but Earns More

Mayer Brown· 5 Apr 2026

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Causes and effects

This Event

US Oil Sanctions Waiver Expires 11 April Amid Confusion

The GL 134A expiry is a binary US policy signal: extension at $121 per barrel directly subsidises Moscow's war revenue; lapse combined with Baltic terminal damage would compound Russia's export crisis.

Led to

GL 134A lapses toward quiet extension

GL 134A event is the direct resolution of ID:2027's binary-choice framing: extension at $121/bbl or lapse on the 11 April expiry date.

Occurred 11 Apr 2026

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Treasury kills $150M-a-day Russian oil waiver

At $121 Urals the waiver was running 2.6x above the $73 barrel design price, making non-renewal a structural inevitability.

Occurred 16 Apr 2026

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Different Perspectives

Turkey (Shakarab consideration)

Ankara serves as one of two Western-adjacent Iran back-channels while Turkish national Gholamreza Khani Shakarab faces imminent execution on espionage charges in Iran. President Erdogan cannot deflect the domestic political crisis that a Turkish execution would trigger, which would force suspension of the mediating role.

Germany (Bundestag gap)

Belgium, Germany, Australia, and France committed Hormuz coalition hardware on 18 May. Germany's Bundestag authorisation for the coalition deployment remains pending, creating a constitutional gap between the commitment announced and the parliamentary mandate required to operationalise it.

IEA and oil market analysts

The IEA's $106 May Brent projection met the market in one session on 20 May as Brent fell 5.16% on diplomatic optimism. Goldman Sachs and Morgan Stanley's two-layer premium framework holds: the kinetic component compressed; the structural insurance component tied to Lloyd's ROE remains unresolved.

Hengaw

Documented the dual Kurdish execution at Naqadeh on 21 May, the two Iraqi-national espionage executions on 20 May, and Gholamreza Khani Shakarab's imminent execution risk. The 24-hour cluster covers two executions at one facility, the first foreign-national espionage executions, and a Turkish national whose death would suspend Ankara's mediation.

Lloyd's of London

Hull rates stand at 110-125% of vessel value on the secondary market; the Joint War Committee has conditioned cover reopening on written ROE from the coalition or PGSA. The Majlis rial bill makes any compliant ROE structurally impossible to draft while the PGSA's yuan portal remains its operational mechanism.

United Kingdom and France (Northwood coalition)

The 26-nation coalition paper requires Lloyd's to see written rules of engagement before Hormuz war-risk cover reopens. The Majlis rial bill adds a second governance incompatibility on top of the unpublished PGSA fee schedule; coalition ROE cannot mention rial without conceding Iranian sovereignty over the strait.