The US Treasury Department's Office of Foreign Assets Control (OFAC) has issued General License 135, authorizing transactions involving Russian-origin diesel fuel.

The license, announced by OFAC, carves out diesel fuel of Russian origin from the reach of certain sanctions restrictions that would otherwise block US persons from dealing in the commodity. General License 135 now sits within the growing body of Russia-related authorizations that OFAC has issued since the escalation of sanctions against Moscow.

What does the new license do?

General License 135 authorizes transactions involving Russian-origin diesel fuel. The authorization means that conduct falling within its scope does not violate the prohibitions that OFAC administers under the Russia sanctions program.

Practitioners should note the precise scope limits of any general license before relying on it. General licenses typically carry definitional restrictions, expiry dates, and reporting conditions, and OFAC retains authority to revoke them. Firms handling Russian-origin diesel fuel should verify that their specific transaction fits the license's terms and monitor OFAC's website for any amendments or revocation.

Who is affected?

The decision affects US persons — and in many cases foreign parties whose dealings touch US jurisdiction — involved in transactions connected to Russian-origin diesel fuel. For compliance teams at banks, traders, shipping firms, and refiners, the new authorization provides a defined safe harbor where the underlying sanctions rules would otherwise apply.

For counsel advising clients in the energy and commodities sectors, the practical consequence is straightforward: transactions involving Russian-origin diesel that meet the conditions of General License 135 may proceed without a specific license application to OFAC. Any conduct outside the license's scope remains subject to the underlying prohibitions and potential civil or criminal penalties.

OFAC's issuance of General License 135 was reported by Lexology on the date of publication.