OFAC issues General License 135 authorizing transactions involving Russian-origin diesel fuel

Overview

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) today issued Russia-related General License 135 (GL 135), “Authorizing Transactions Related to the Sale, Delivery, Offloading, and Importation of Diesel Fuel of Russian Federation Origin.” GL 135 authorizes, subject to the express limitation discussed below, certain transactions involving diesel fuel of Russian Federation origin through April 7, 2027.

Key features of GL 135 

GL 135 authorizes all transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, or the Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589, that are related to the sale, delivery, offloading or importation of diesel fuel of Russian Federation origin. We note that the authorization expressly includes importation into the United States and remains in effect through 12:01 a.m. Eastern Daylight Time on April 7, 2027.

Notably, the authorization is subject to an express limitation. GL 135 does not authorize any debit to an account on the books of a US financial institution of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation or the Ministry of Finance.

The scope of GL 135 is also important to note. The license specifically authorizes transactions otherwise prohibited under the two Russia-related sanctions programs identified above but does not provide authorization for separate prohibitions arising under other OFAC sanctions programs. OFAC FAQ 74 similarly explains that a general license authorizes certain categories of transactions that would otherwise be prohibited pursuant to a particular sanctions program.

Accordingly, we emphasize that where a counterparty is subject to sanctions under both an authority covered by GL 135 and a separate OFAC sanctions program, GL 135 would not itself authorize conduct that remains prohibited under the separate program. For example, if a counterparty were blocked under both a Russia-related authority covered by GL 135 and a separate Iran-related sanctions authority, GL 135 would not itself provide authorization for a transaction that remains prohibited under the applicable Iran-related sanctions program. Companies and financial institutions considering reliance on GL 135 should therefore consider whether other OFAC sanctions authorities independently restrict the proposed transaction.

Interaction with existing legislation and congressional response

GL 135 also raises questions regarding its interaction with the Ending Importation of Russian Oil Act of 2022. That statute prohibits the importation into the United States of Russian-origin products classified under Chapter 27 of the Harmonized Tariff Schedule and establishes a specified process for terminating that prohibition, including congressional consultation, presidential certification and a 90-day congressional review period. We note although GL 135 expressly authorizes transactions involving the importation into the United States of Russian-origin diesel that would otherwise be prohibited under the two OFAC sanctions programs identified in the license, it does not expressly address the 2022 statute. 

Additionally, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 expressly preserves Treasury’s authority to issue new general licenses but does not expressly amend or suspend the separate 2022 import prohibition. We previously published a blog post concerning the scope of that Act. Questions may therefore arise regarding the extent to which GL 135 independently authorizes imports otherwise covered by the statutory ban. We are closely monitoring further government guidance and related developments on this topic.

The authorization has also prompted bipartisan congressional opposition. On October 11, four Republican and three Democratic senators issued a joint statement asserting that the decision to permit Russian diesel imports runs directly counter to the 2022 law and calling on the Administration to reverse course. Separately, U.S. Representative Brian Fitzpatrick announced plans for bipartisan legislation, reportedly titled the “Ronald Reagan Peace Through Strength Act,” that would block purchases of Russian oil. As of October 12, 2026, no introduced bill text for the proposal had been identified in publicly available reporting.

We are happy to discuss any of the topics above in further detail and will update this post as further details emerge.

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