OFAC extended the Lukoil International licence to 22 October and changed only the dates

On 18 September 2026 the US Treasury's Office of Foreign Assets Control replaced one Lukoil licence with another. General Licence 131J supersedes 131I "in its entirety", and almost nothing happened: the sale of Lukoil International GmbH can still be negotiated, its businesses outside Russia can still trade, and the clock now reads 22 October.

OFAC's notice that day led with Ethiopia, whose sanctions emergency had expired and whose SDN entries were removed. The Lukoil licence was the second item, and the one with a deadline.

We compared the 131I and 131J PDFs word by word. Paragraphs (a) to (d) are identical. What differs:

That is the whole change. The two FAQs OFAC amended the same day, 1224 and 1225, changed the same way when set against the copy the Internet Archive kept on 26 August. The licence letter and the dates were updated, 131J was added to the list of versions in 1225, and not a word of substance changed.

There is no new carve-out to learn and no new condition to meet. The information is the date. FAQ 1225 lists ten versions since December 2025, 131A to 131J; the last three ran 29, 30 and 34 days.

Paragraph (a) permits the transactions "ordinarily incident and necessary" to negotiating and entering contracts with Lukoil or its affiliates for the sale of Lukoil International GmbH, or of anything in which it holds 50 percent or more. OFAC's term for the group is LIG Entities. The contracts must say that performance depends on a separate OFAC authorisation. A bid in a public tender counts.

Paragraph (b) permits what is ordinarily incident and necessary to maintain or wind down the operations, contracts and agreements of LIG Entities. Paragraph (c) lets their blocked accounts be debited and credited for that.

Paragraph (d) takes three things away: unblocking any property, dealings with any other blocked person, and "the transfer of funds to any person or account located in the Russian Federation". For a payment desk the third is the one that decides cases.

One point of reading. FAQ 1224 calls the target "LIG's majority-owned subsidiaries". The licence says 50 percent or greater, so a 50-50 joint venture is inside the licence's words and outside the FAQ's. The licence is the authorisation; the FAQ is OFAC's summary of it.

Membership of the class turns on ownership, not on a name, so a name search cannot establish it. The licence says what is permitted once you know who is in. Working that out takes an ownership chain: the 50 percent rule applied to a real group.

FAQ 1224 adds what a sale has to look like. OFAC expects it to sever Lukoil International from Lukoil completely, to put any money owed to Lukoil in a blocked account under US jurisdiction, and to give Lukoil no up-front value, for example through asset or share swaps. It also expects to require buyers to come back to OFAC before they sell on any material asset. None of that is a licence. It describes what a licence for the sale would need, and none has been published.

"Through 12:01 a.m." is easy to read as "through 22 October". It means the authorisation ends at the first minute of the day. In Eastern time the last full day is Wednesday 21 October. In UTC the cut-off is 04:01 on the 22nd, and in Central Europe, still on summer time until 25 October, it is 06:01.

The history suggests how to plan, though not what OFAC will do:

OFAC's recent-actions index runs to 8 October and lists no Lukoil action from 23 September to 8 October; the one Russia-related licence in that span, GL 13S of 8 October, concerns Directive 4. We did not open the index page covering 19 to 22 September. FAQ 1225 still lists 131J as the newest. The last two replacements came one or two days before expiry; that is a habit, not a commitment. A file that depends on the licence should carry both outcomes: a renewal, and 22 October with no licence.

General Licence 128C covers a narrower thing and ends later. It authorises transactions involving LIG Entities, naming Lukoil North America LLC and Lukoil Americas Corporation, that are necessary to buy goods and services from physical retail service stations outside Russia. Maintaining, operating or winding down those stations is covered too. It runs to 12:01 a.m. on 29 October.

If nothing is renewed, then between 22 and 29 October only the station business is licensed. A supplier, lessor or card processor whose Lukoil exposure is the forecourt still has a licence for that week. One whose exposure is the wider group does not.

1. List every counterparty that is Lukoil International GmbH or may be owned 50 percent or more by it. Fuel suppliers, forecourt operators, lessors, lubricant distributors and insurers are where to look.
2. For each, write down which licence you rely on: 131J paragraph (b), or 128C. The expiry differs by a week.
3. Put 21 October in the calendar, in Eastern time, with a named owner.
4. Check the destination of every payment. Paragraph (d)(3) bars any transfer of funds to a person or account located in the Russian Federation. GL 128C carries the same bar in paragraph (c)(4).
5. Check OFAC's recent-actions page daily from 19 October for a 131K.
6. Store the licence and the paragraph next to the match, not only the fact that a name matched.

A screening result says that a counterparty matches a blocked party, not which licence, if any, lets you deal with it. That has to sit in your own record next to the match. The screening API returns the matched list entry as structured data, so the licence number, paragraph and expiry can be saved in the same record and found again when an auditor asks.

This reports what OFAC published on 18 September 2026 and what its general licences and FAQs said on 9 October 2026. It is not legal advice and takes no position on the Lukoil designation or on the sale.

We did not check which Lukoil International entities appear on the SDN List, so we do not say how many there are. We did not read earlier versions of FAQs 1224 and 1225 beyond the 26 August copy, and we did not check how the EU or the UK treat Lukoil; none of this speaks to their law. We do not know whether OFAC will issue a 131K, whether the sale talks are going anywhere, or who the bidders are. OFAC's documents do not say.