Six Days After Question To OFAC, General License 134 Amended To 134a: Adding No Russian Oil For Cuba
/On 13 March 2026, the U.S.-Cuba Trade and Economic Council submitted a question to the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury:
“Does OFAC General License Number 34 issued on 12 March 2026 apply to oil sourced from the Russian Federation which was loaded onto a vessel prior to 12 March 2026 for which the destination is the Republic of Cuba?”
12 March 2026- GENERAL LICENSE 134
Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 12, 2026
(a) Except as provided in paragraph (b) of this general license, all transactions prohibited by the above-listed authorities that are ordinarily incident and necessary to the sale, delivery, or offloading of crude oil or petroleum products of Russian Federation origin loaded on any vessel, including vessels blocked under the above listed authorities, on or before 12:01 a.m. eastern daylight time, March 12, 2026 are authorized through 12:01 a.m. eastern daylight time, April 11, 2026.
Note 1 to paragraph (a). Transactions that are ordinarily incident and necessary to the sale, delivery, or offloading of such crude oil or petroleum products include transactions for the safe docking and anchoring of vessels carrying such crude oil or petroleum products; the preservation of the health or safety of the crew of any such vessel; emergency repairs or environmental mitigation or protection activities relating to any such vessel; and services such as vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage. Russian Federation-origin crude oil and petroleum products subject to this general license include those produced by entities sanctioned under the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, or the Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589. (b) This general license does not authorize any other transactions or activities prohibited by any other Executive order or by any part of 31 CFR chapter V not referenced in this general license, including any transaction or activity involving Iran, the Government of Iran, or Iranian-origin goods or services that is prohibited by the Iranian Transactions and Sanctions Regulations (31 CFR part 560), except as authorized by paragraph (a).
19 March 2026- GENERAL LICENSE 134A
Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 12, 2026
(a) Except as provided in paragraph (b) of this general license, all transactions prohibited by the above-listed authorities that are ordinarily incident and necessary to the sale, delivery, or offloading of crude oil or petroleum products of Russian Federation origin loaded on any vessel, including vessels blocked under the above listed authorities, on or before 12:01 a.m. eastern daylight time, March 12, 2026 are authorized through 12:01 a.m. eastern daylight time, April 11, 2026.
Note 1 to paragraph (a). Transactions that are ordinarily incident and necessary to the sale, delivery, or offloading of such crude oil or petroleum products include transactions for the safe docking and anchoring of vessels carrying such crude oil or petroleum products; the preservation of the health or safety of the crew of any such vessel; emergency repairs or environmental mitigation or protection activities relating to any such vessel; and services such as vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage. Russian Federation-origin crude oil and petroleum products subject to this general license include those produced by entities sanctioned under the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, or the Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589. (b) This general license does not authorize: (1) Any transaction involving a person located in or organized under the laws of the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, the Covered Regions of Ukraine, as defined by E.O. 14065, the Crimea Region of Ukraine, as defined by E.O. 13685, or any entity that is owned or controlled by or in a joint venture with such persons; or (2) Any other transactions or activities prohibited by any other Executive order or by any part of 31 CFR chapter V not referenced in this general license, including any transaction or activity involving Iran, the Government of Iran, or Iranian-origin goods or services that is prohibited by the Iranian Transactions and Sanctions Regulations (31 CFR part 560), except as authorized by paragraph (a). (c) Effective March 19, 2026, General License No. 134, dated March 12, 2026, is replaced and superseded in its entirety by this General License No. 134A.
Link To 134
Link To 134a
