Sanctions Watch | Weekly Vol. 171

Sanctions Watch Vol 171

In the latest edition of our Sanctions Watch weekly digest, we present significant updates on sanction watchlists and regulatory developments.

OFAC Extends Authorization for Lukoil International Sale Negotiations and Maintenance Activities Through October 22, 2026

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 131J under the Russian Harmful Foreign Activities Sanctions Regulations. The license authorizes certain transactions ordinarily necessary to negotiate and enter into contingent contracts involving Public Joint-Stock Company Oil Company Lukoil or its affiliates for the sale, disposition, or transfer of Lukoil International GmbH (LIG) and entities in which LIG holds, directly or indirectly, a 50% or greater interest. These authorizations remain effective through 12:01 a.m. EDT on October 22, 2026, and performance of any resulting contract remains subject to separate OFAC authorization.

GL 131J also permits transactions ordinarily necessary for the maintenance or wind-down of LIG Entities’ operations, contracts, or agreements through the same deadline and allows blocked accounts of LIG Entities to be used for those authorized activities.

The license does not generally authorize the unblocking of property, otherwise prohibited transactions involving other blocked persons, or transfers of funds to persons or accounts located in Russia. Effective September 18, 2026, GL 131J replaces and supersedes GL 131I, which was dated August 20, 2026.

OFAC Issues General License 52C Authorizing Certain Transactions with Venezuela’s PdVSA

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 52C under the Venezuela Sanctions Regulations, authorizing certain otherwise prohibited transactions involving Petróleos de Venezuela, S.A. (PdVSA) and entities in which PdVSA owns, directly or indirectly, a 50% or greater interest. The authorization applies to qualifying established U.S. entities, defined as entities organized under U.S. law on or before January 29, 2025.

Contracts with PdVSA or PdVSA Entities must provide for dispute resolution proceedings in the United States, United Kingdom, France, or Singapore. Monetary payments to blocked persons, other than specified local taxes, permits, or fees, must generally be directed to designated Foreign Government Deposit Funds or another account instructed by the U.S. Treasury. The license also authorizes certain necessary transactions involving the Government of Venezuela and specified contract-execution activities by blocked PdVSA officials acting in their official capacities.

GL 52C retains significant restrictions, including certain transactions involving sanctioned debt, other SDNs, specified Russia-, Iran-, North Korea-, Cuba- and China-linked parties, blocked vessels, and CITGO-related governance changes.

The license also introduces reporting requirements for certain exports of Venezuelan-origin oil or petrochemical products outside the United States. GL 52C replaces and supersedes GL 52B effective September 14, 2026.

OFAC Issues General License 5Z Authorizing PdVSA 2020 Bond Transactions from November 5, 2026

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5Z under the Venezuela Sanctions Regulations, addressing transactions involving the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5% Bond.

Under GL 5Z, beginning November 5, 2026, OFAC authorizes all transactions related to, the provision of financing for, and other dealings in the PdVSA 2020 8.5% Bond that would otherwise be prohibited under Executive Order 13835, as amended by Executive Order 13857 and incorporated into the Venezuela Sanctions Regulations.

Authorization is limited in scope. GL 5Z does not permit transactions or activities that remain otherwise prohibited under the Venezuela Sanctions Regulations or any other part of 31 CFR Chapter V. Effective September 16, 2026, GL 5Z replaces and supersedes General License 5Y, which was issued on August 3, 2026.

Switzerland Tightens Belarus Sanctions, Targeting Crypto Transactions, Services and Trade

Switzerland has expanded its sanctions regime against Belarus through amendments adopted by the Swiss Federal Council on September 18, 2026. Most of the changes entered into force on September 19, 2026, strengthening restrictions across financial services, crypto-assets, trade, and other economic activities.

A significant element is the introduction of restrictions involving crypto-assets and central bank digital currencies. The amended ordinance prohibits direct or indirect participation in transactions involving designated crypto-assets or central bank digital currencies, as well as assistance with their development. It also prohibits legal persons, including financial institutions, and natural persons from conducting specified transactions with Belarus-based crypto-asset service providers and exchange or transfer platforms, subject to limited exemptions for certain official diplomatic and international-organization activities. The Digital Belarusian Ruble is specifically identified in Annex 14a as subject to the transaction ban.

The measures also broaden service-related restrictions. They prohibit tourism-related services to Belarus and add managed security services to the restricted categories. Other services supplied to the Belarusian government and specified public bodies, enterprises or agencies may require authorization from Switzerland’s State Secretariat for Economic Affairs (SECO).

Additional provisions address loans and credit, asset freezes, transactions connected with certain claims pursued in third countries, and expanded controls covering industrial and economically important goods. Most amendments took effect on September 19, while the managed-security-services provision is scheduled to enter into force on October 20, 2026.

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Sanctions Watch is a weekly recap of events and news related to sanctions around the world.