Husch BlackwellยทSANCTIONS / EXPORT CONTROLS

OFAC General License 135 Temporarily Eases Sanctions on Russian Diesel

OFAC issued General License 135 on October 9, 2026 authorizing transactions tied to the sale, delivery and importation of Russian diesel fuel, opening a time-limited compliance window for traders, refiners and shippers.

On October 9, 2026, the US Treasury Department's Office of Foreign Assets Control issued General License No. 135, described as authorizing transactions related to the sale, delivery, offloading and importation of diesel fuel of Russian origin. The license appears to be a temporary, window-based authorization rather than a broader lifting of measures, and the underlying alert text available to us is truncated, so the precise scope of covered parties, volumes, counterparties and the expiry date should be confirmed against the license and any accompanying FAQs before reliance.

Why sophisticated counsel should care: Russia-related energy flows have been among the most heavily sanctioned categories for three years, and buyers, sellers, terminal operators, banks and charterers have each faced secondary sanctions and rejection risk. A general license of this kind typically creates a safe harbor from enforcement only for activity matching its terms exactly; a mis-scoped transaction can still produce blocking, civil penalty or reputational exposure, and it can affect sanctions representations in financing documents, insurance, offtake contracts and import filings.

Concrete action: run an eligibility check against the license text line by line, screen counterparties and vessels for restricted persons, and align contract and shipping documentation with the authorization window. Watch for follow-on OFAC FAQs, license amendments, expiry or extension, and parallel EU or UK measures on Russian refined products.

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