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Iran Conflict 2026
1OCT

15 days: Russia's crude waiver lapses

1 min read
19:22UTC

OFAC let General License 134C, the waiver allowing purchase of pre-cut-off Russian crude, lapse on 17 June with no successor, a 15-day gap and the longest of the war.

ConflictAssessed
Key takeaway

OFAC's 15-day silence on the crude waiver is the longest of the war.

The US Treasury's Office of Foreign Assets Control (OFAC), the bureau that runs American sanctions, let General License 134C lapse on 17 June with no successor issued as of 1 July⁠1. The licence is the waiver that lets buyers take Russian crude loaded before a cut-off date, and its expiry has now stretched into a 15-day gap.

Every earlier lapse was bridged within one or two days; this is the longest of the war⁠2. A permanent lapse would strip the legal cover under which some buyers still take Russian crude, tightening the channel further. Whether OFAC issues a General License 134D or lets the waiver die will decide how much Russian oil can move without sanctions risk.

Washington's mediation has been dormant since Secretary of State Marco Rubio declared it stagnant on 22 May, and Vladimir Putin's published calendar shows no US or Ukrainian diplomatic contact in the week⁠3. The unrenewed waiver sits inside that same absence, one of the few levers Washington still holds over Russian oil revenue, currently left idle.

Deep Analysis

In plain English

The US Treasury has a rolling permission slip, called a general licence, that lets buyers finish paying for Russian oil cargoes that were already loaded onto ships before a cut-off date. Without it, completing the deal risks breaking US sanctions. That permission slip expired on 17 June and, as of 1 July, hadn't been renewed, a two-week gap where the usual turnaround is a day or two. Buyers still paying for cargoes loaded before 17 June now have no OFAC paperwork to show if Washington asks.

Deep Analysis
Root Causes

The GL 134 waiver series requires active renewal by OFAC every cycle rather than running on autopilot, so any gap in Treasury's attention or willingness produces an automatic lapse rather than a deliberate one-off decision.

With no successor issued as of 1 July, the lapse has already outlasted every prior GL 134 renewal gap combined, suggesting the drift is now structural rather than an administrative delay.

What could happen next?
  • Risk

    Buyers and insurers still finalising already-loaded Russian cargoes face sanctions exposure until a successor licence appears.

  • Meaning

    A 15-day gap, far longer than any prior GL 134 renewal delay, suggests Treasury's routine sanctions bureaucracy has itself become a source of uncertainty for the oil trade.

First Reported In

Update #22 · Belarus relays go dark on Kyiv's deadline

treasury.gov· 2 Jul 2026
Read original →
Different Perspectives
Russia
Russia
Russia vetoed the same renewal on 17 September, arguing that Britain, France and Germany never validly triggered the snapback that reimposed the pre-2015 UN resolutions. No panel was ever seated under that mandate, so the UN list decays fastest for states that screen against it rather than against the American one.
China
China
China vetoed renewal of the UN sanctions monitoring mandate on 17 September, arguing that Resolution 2231 terminated on 18 October 2025 and that the Security Council should drop Iran's nuclear file altogether. On that reading there is nothing to monitor, so the sanctions survive and their enforcement does not.
Iraq
Iraq
Baghdad saw the last American counter-Islamic State troops leave its territory on 30 September, completing a timetable it agreed with Washington in September 2024. Iraqi airspace deconfliction passes to Baghdad, which still has an open inquiry into the Maysan drone launches that has named nobody.
Pakistan
Pakistan
Treasury names Waseem Pasha Tajammal of Rawalpindi as the Cavalier group's chairman and places one of the designated incorporations in Islamabad. QatarEnergy separately told Pakistan that liquefied natural gas cargo cancellations would run through November, so Islamabad carries an enforcement question and a supply gap at once.
Turkey
Turkey
Treasury named a Cavalier Dynamics company incorporated in Istanbul among the ten nodes it designated on 29 September, and Ankara has published no response. Turkey imported a record 120,000 barrels a day of Indian diesel in August, cutting Russia's share of its diesel imports to 20 per cent.
India
India
Suraj Yadav, a wiper from Uttar Pradesh, was killed aboard the Cape Dao on 23 September, and 19 of the ship's 20 Indian crew were taken off alive. India's September imports ran at 575,000 barrels a day from Iraq and 566,000 from Saudi Arabia, back to pre-conflict rates.