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Iran Conflict 2026
16MAY

OFAC GL 134B expires 16 May, no successor

4 min read
12:41UTC

OFAC General License 134B, authorising Russian crude transactions, expires at 12:01 EDT on 16 May 2026. No GL 134C has appeared in the OFAC actions feed as of 13 May, making this the second consecutive non-extension.

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Key takeaway

GL 134B expires 16 May with no successor visible: second consecutive non-extension, threatening stranded cargoes.

OFAC (Office of Foreign Assets Control) General License 134B expires at 12:01 EDT on 16 May 2026 1. No GL 134C has appeared in OFAC's recent actions feed as of 13 May. GL 134B authorises transactions in Russia-origin crude oil and petroleum products loaded onto vessels on or before 17 April; expiry without a successor would strand cargoes currently at sea and remove the legal certainty that shadow-fleet operators and Asian refiners have relied on since the licence series began in March 2026.

This would be the second consecutive non-extension in the sequence. GL 134A expired on 16 April without renewal, triggering the redesignation of Rosneft and Lukoil as Specially Designated Nationals (SDN) . Treasury then issued GL 134B one day later , keeping the channel open through 16 May. That single-day reflexive extension on 17 April is not a reliable precedent: it was a patch on an unexpected cliff, not a standing commitment to rolling authorisation. If GL 134B expires hard, the 17 April response is the model for how Treasury acts, but only if the same internal calculus that produced the one-day patch still holds.

The fiscal timing makes the cliff consequential regardless of which way it lands. Russia's National Wealth Fund (NWF) held $49.1 billion in liquid assets on 1 May, with the Finance Ministry now purchasing 110 billion roubles in NWF assets in May to recapitalise . Oil and gas revenues fell 38.3% year-on-year in January-April 2026, as covered separately in this briefing. With Brent at $107/barrel, each Russian barrel that cannot leave legally costs Moscow at Urals rates near $80-85. Every blocked cargo at a high oil price is the most expensive version of the sanctions mechanism. If GL 134C does not appear before 16 May, Asian refinery contract adjustments and potential Treasury SDN follow-ons are the downstream signals to watch.

Deep Analysis

In plain English

When the US sanctions Russia, it does not always switch everything off at once. Instead, it issues 'general licences': temporary permissions that let companies finish existing contracts without breaking the law, so they can wind down their business with Russia gradually. GL 134B covers shipments of Russian crude oil that were already loaded onto tankers before a certain date. Without it, those ships are technically carrying cargo the US says nobody can legally help with, which means Western insurers would have to withdraw their cover. The licence expires on 16 May. If no new one appears, the companies still in this wind-down process face a legal problem. Russia can work around it, as it has built its own shadow insurance system, but the process costs more and takes time.

What could happen next?
  • Consequence

    Western P&I clubs may withdraw cover from Russian-cargo wind-down voyages, raising Russian oil export transaction costs by an estimated 15-25% and accelerating Russia's shift to RNRC coverage.

  • Risk

    A permanent move of Russian oil logistics outside Western insurance and legal architecture reduces the leverage that future US administrations would have to apply financial pressure on Russia's energy sector.

Sources:Baker McKenzie Sanctions News·Baker McKenzie Sanctions News
Mentions:OFAC →General License 134B →Rosneft →Lukoil →Russia →Baker McKenzie →Moscow →Iran →US Treasury →National Wealth Fund →Urals →China →Specially Designated Nationals (SDN) →Kpler →Russian Finance Ministry →Brent Crude →
First Reported In

Update #16 · 800 drones, three ceasefires, one cliff

Baker McKenzie Sanctions News· 13 May 2026
Read original →
Causes and effects
Caused by
Treasury kills $150M-a-day Russian oil waiver
GL 134A non-renewal and Rosneft/Lukoil SDN redesignation on 16 April established the second-cliff pattern the 16 May GL 134B expiry now repeats.
Occurred 16 Apr 2026
Read story →
OFAC quietly extends Russia crude waiver
OFAC issued GL 134B on 17 April as a one-day reflexive extension after 134A lapsed; its 16 May expiry is the direct target of the current cliff.
Occurred 17 Apr 2026
Read story →
This Event
OFAC GL 134B expires 16 May, no successor
If GL 134B expires without a successor, cargoes already at sea lose legal cover and shadow-fleet operators face immediate compliance uncertainty, compounding a Russian fiscal year already 38.3% below target on oil revenues.
Different Perspectives
India (BRICS meeting host, grey-market beneficiary)
India (BRICS meeting host, grey-market beneficiary)
New Delhi hosted the BRICS foreign ministers' meeting on 14 May that Araghchi attended under the Minab168 designation, giving India a front-row seat to Iran's diplomatic positioning. India's state refiners have been absorbing discounted Iranian crude through grey-market routing since April; Brent at $109.30 means every barrel sourced outside the formal market generates a structural saving.
Hengaw / Kurdish human rights monitors
Hengaw / Kurdish human rights monitors
Hengaw's daily reports from Iran's Kurdish provinces remain the sole independent cross-check on Iran's judicial activity during the conflict. Two executions across Qom and Karaj Central prisons on 15 May and five Kurdish detentions on 15-16 May indicate the wartime judicial pipeline is operating independently of military tempo.
Pakistan (mediator and bilateral partner)
Pakistan (mediator and bilateral partner)
Islamabad spent its diplomatic capital as the US-Iran MOU carrier to secure LNG passage for two Qatari vessels through a bilateral Pakistan-Iran agreement, spending its mediation credit for direct economic gain. China's public endorsement of Pakistan's mediatory role on 13 May is the structural reward.
China and BRICS bloc
China and BRICS bloc
Beijing endorsed Pakistan's mediatory role on 13 May, one day after the BRICS foreign ministers' meeting in New Delhi. Chinese state banks are processing PGSA yuan toll payments; China has not commented on its vessels' continued Hormuz passage, but benefits structurally from a non-dollar toll system it did not design.
Iraq (bilateral passage partner)
Iraq (bilateral passage partner)
Baghdad negotiated a 2-million-barrel VLCC transit without paying PGSA yuan tolls, offering political alignment in lieu of cash. Iraq's position inside Iran's adjacent bloc makes it the natural first bilateral partner and a template for how Tehran structures passage deals with states that cannot afford Western coalition membership.
Bahrain and Qatar (Gulf signatories)
Bahrain and Qatar (Gulf signatories)
Both signed the Western coalition paper while hosting US Fifth Fleet and CENTCOM's Al Udeid base, respectively. Qatar occupies the sharpest contradiction: it is on coalition paper while simultaneously receiving LNG passage through the bilateral Iran-Pakistan track, a position Doha has tacitly accepted from both sides.