Skip to content
Briefings are running a touch slower this week while we rebuild the foundations.See roadmap
Iran Conflict 2026
10APR

US Oil Sanctions Waiver Expires 11 April Amid Confusion

2 min read
08:05UTC

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.

ConflictDeveloping
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.

First Reported In

Update #11 · Russia Sells Less Oil but Earns More

Mayer Brown· 5 Apr 2026
Read original
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.
Different Perspectives
Lloyd's of London
Lloyd's of London
The Joint War Committee left Hormuz war-risk premiums at $10-14 million per voyage on 25 May, declining to move on Brent's 5% fall. The JWC's protocol requires a UN Security Council resolution or bilateral government certification letter before de-listing, and neither has arrived: a verbal understanding does not satisfy the formal condition the reinsurance market's treaty terms require.
Gulf Arab producers
Gulf Arab producers
Saudi Arabia and UAE depend on Hormuz for their own crude exports; Aramco CEO Nasser has warned no oil market recovery arrives until 2027 if the blockade continues past mid-June. Monday's $98.96 Brent settlement shortens nothing for Gulf producers without a signed instrument and a Pentagon mine-clearance timeline that runs up to six months post-ceasefire.
Qatar
Qatar
Qatar holds $12bn of frozen Iranian assets at the centre of the sequencing dispute but cannot release them without explicit US Treasury authorisation, given the original freeze was a US instrument. As the asset-holding state, Qatar's leverage is real but passive: it is the escrow holder, not the decision-maker, and any resolution requires US Treasury sign-off that Trump has withheld.
Pakistan
Pakistan
With both Prime Minister Sharif and army chief Munir simultaneously in Beijing on 25 May, Pakistan has for the first time consolidated its civilian and military mediation tracks under China's roof. Munir's direct Tehran-to-Beijing flight signals that the security and financial threads of the sequencing problem are now being worked in parallel rather than sequentially.
China
China
Beijing hosted Pakistan's principal mediators and Iran's China envoy Ghalibaf simultaneously on 25 May while its banking regulator capped new state-bank lending to five sanctioned refiners. China is simultaneously the most credible third-party underwriter of the $12bn sequencing and the state whose institutions face live OFAC secondary-sanctions exposure if the deadlock persists through GL V's expiry.
United States
United States
Trump posted on 24 May that the blockade holds until a deal is certified and signed, ruling out the informal MOU structure both sides had been building. The 'certified, and signed' condition is the first operational bar Trump has attached in 87 days, but it arrived without an executive instrument, maintaining the gap between posted ultimatum and signed US policy.