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US Oil Sanctions Waiver Expires 11 April Amid Confusion

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10:39UTC

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

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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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

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.