Publication of Russian Harmful Foreign Activities Sanctions Regulations Web General Licenses 55F and 115D

What it does

• •GL 55F authorizes transactions related to maritime transport of crude oil from the Sakhalin-2 project solely for import into Japan, and authorizes transactions with Gazprombank and entities it controls that relate to Sakhalin-2, through December 18, 2026.
• •GL 115D authorizes transactions with 13 specified Russian financial institutions and the Central Bank of Russia that are undertaken solely to maintain or support civil nuclear projects initiated before November 21, 2024, through December 18, 2026.
• •Both licenses replace and supersede previous general licenses (55E and 115C respectively) issued December 17, 2025, and explicitly exclude certain prohibited transactions involving correspondent accounts, certain government accounts, and other blocked persons unless separately authorized.

Why it matters

• •The licenses provide narrow carve-outs from broader Russian sanctions regulations, allowing specific energy-related transactions (Sakhalin-2 crude oil and civil nuclear projects) to proceed under defined conditions and timelines.
• •The restrictions on correspondent accounts and Central Bank transactions ensure the licenses do not circumvent core financial sanctions while permitting targeted economic activities.

Who is affected

• •Entities engaged in maritime transport of Russian crude oil from Sakhalin-2 destined for Japan and parties transacting with Gazprombank related to that project.
• •Financial institutions (Gazprombank, Sberbank, VTB Bank, Alfa-Bank, Otkritie, Vnesheconombank, and others) and the Central Bank of Russia engaged in civil nuclear energy transactions initiated before November 21, 2024.

What happens next

These general licenses remain in effect as published on OFAC's website and expire on December 18, 2026, unless further action is taken by OFAC.