1JUN

OFAC GL 134B expires 16 May, no successor

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10:39UTC

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.

Source Landscape

This story draws on neutral-leaning sources

Primary parallel: The Iran oil sanctions architecture from 2012 to 2015 used a comparable licence-cliff mechanism: the US Treasury issued successive short-duration wind-down licences, each with a non-renewal threat, to gradually tighten compliance without triggering an immediate oil price shock.

The GL 134A-134B sequence mirrors that playbook. The Iran precedent also showed the limits: within 18 months, Iran had routed approximately 60% of its exports through a China-Iran direct payment channel that bypassed the dollar system entirely.

Counter-parallel: Russia's shadow fleet is already larger (estimated 450-600 vessels) and more diversified than Iran's was in 2012, meaning the timeline to full workaround completion is shorter. Carnegie Endowment's Edward Fishman has documented that Western sanctions on Russia's oil sector have consistently underperformed their stated targets by 30-40% due to third-country substitution.

GL 134B covers cargoes of Russian-origin crude loaded on or before 17 April 2026. At an average of 750,000 barrels per tanker and an Atlantic transit time of 10-20 days, roughly 30-50 tankers are potentially within the coverage window. At $107/barrel (Brent benchmark), the cargo value exposure is approximately $2.4-4 billion.

London's International Group of P&I Clubs faces the larger economic exposure. The London market's International Group of P&I Clubs has used successive OFAC general licences as the legal basis for maintaining cover on wind-down voyages.

A non-renewal forces clubs to either withdraw cover, raising Russian crude insurance costs by an estimated 15-25% according to Clarksons Research, or accept the compliance risk of operating without US legal backing. Both outcomes raise Russian oil export costs, but neither shuts the flow.

Consensus view: Baker McKenzie's sanctions practice and Holman Fenwick Willan's shipping team both assess that a GL 134B expiry without GL 134C would create an immediate cargo-stranding problem for approximately 30-40 tankers carrying Russian-origin crude currently within the Atlantic transit window.

The practical effect is not a full sanctions tightening, since Russia's shadow fleet operates largely outside US jurisdiction. Rather, it removes the last piece of legal certainty that Western P&I (Protection and Indemnity) clubs have used to justify continued cover for wind-down voyages.

Counter-view: The Russian Energy Ministry and shipping analysts at Kpler argue the shadow fleet has already successfully decoupled from Western P&I cover following GL 134A's non-renewal in April, with the Russian National Reinsurance Company stepping in for approximately 85 vessels. A GL 134B expiry therefore has a diminishing marginal impact on Russian export volumes, though it raises transaction costs and creates additional compliance risk for third-country intermediaries.

Key tension: Whether GL 134B's expiry accelerates the structural shift of Russian oil logistics entirely outside Western legal and insurance architecture, which would represent a long-term Russian gain, or whether it creates enough short-term disruption to reduce export volumes materially before Russia can fully substitute.

Sources:Baker McKenzie Sanctions News·Baker McKenzie Sanctions News

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

First Reported In

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

Baker McKenzie Sanctions News· 13 May 2026

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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

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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

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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.

Led to

Treasury Drops Cuba From Russian-Crude Waiver

GL 134B expiry on 16 May triggered the 48-hour gap before GL 134C was issued on 18 May

Occurred 18 May 2026

Read story →

Different Perspectives

China

Beijing has not publicly commented on the dual Oreshnik launch. China's declared position of urging restraint and dialogue sits awkwardly alongside its continued economic ties with Russia; the weapons escalation tests whether Beijing's neutrality framing can survive a European IRBM normalisation event.

IAEA

Director General Grossi condemned the ZNPP reactor-6 turbine building strike and stated "there should be no attack of any kind from or against the plant." The agency confirmed normal radiation levels but has not resolved attribution; Rosatom CEO Likachev warned the region is "one step closer to an incident."

Turkey

Ankara hosted Istanbul Round 2 at Ciragan Palace on 2 June and secured a 1,200-for-1,200 prisoner exchange, consolidating Turkey as the war's sole diplomatic venue after Rubio confirmed US mediation has ended. Erdogan's leverage over both parties grows with each round.

European Union

EU Ambassador Mathernova answered Lavrov's evacuation demand with "We stay in Kyiv. We stay with Ukraine." The Verkhovna Rada approved the EUR 90bn EU loan on 28 May; the EUR 9.1bn first tranche, the EU's first explicit defence-procurement financing, arrives mid-June.

United States

Rubio declared US mediation stagnated on 22 May and confirmed no talks were occurring, then received Lavrov's evacuation demand three days later without ordering embassy drawdown. Washington's leverage now runs through the GL 134C sanctions cliff on 17 June rather than any active diplomatic channel.

Ukraine

Zelenskyy called Russia's 2-3 day ceasefire counter-offer at Istanbul Round 2 "shortsighted" and submitted a full peace memorandum covering EU membership, international guarantees, phased sanctions relief and frozen-asset reparations. Kyiv's position is that a partial ceasefire freeze aids Russian reconstitution; only an all-domain 30-day pause is acceptable.