OFAC (Office of Foreign Assets Control) General License 134B expires at 12:01 EDT on 16 May 20261. 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.
