Sanctions Alert: OFAC Authorizes US Imports of Russian Diesel, But Beware of Limitations

On October 9, 2026, OFAC issued General License 135, which temporarily authorizes certain transactions involving Russian-origin diesel fuel. The update occurs against the backdrop of ongoing regional instability and follows recent US legislation targeting Russia’s energy sector, raising uncertain but potential relief for global energy markets and service providers.

Against a backdrop of rising diesel prices worldwide, the US Office of Foreign Assets Control (OFAC) issued General License No. 135 (GL 135 or the GL) on October 9, 2026. GL 135 temporarily authorizes certain transactions involving Russian-origin diesel fuel through April 7, 2027. The issuance of GL 135 follows a same-day social media announcement from the US President that the US reached a deal with Russia to immediately release 300,000 tons of diesel fuel to global markets, with additional amounts to follow over the coming months. The GL, however, faces legal uncertainty, which may warrant caution.

GL 135 Details

GL 135 authorizes “all transactions” otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations or the Ukraine-/Russia-Related Sanction Regulations that are related to the sale, delivery, offloading, or importation, including into the US of Russian-origin diesel fuel for a 6-month period.

GL 135 notes, however, that it does not authorize debits 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.

Statutory Context

In April 2022, the US enacted with the Ending Importation of Russian Oil Act (22 USC § 8923 note) (the Russian Oil Act). This legislation prohibited imports of certain Russian-origin oil products into the United States, including diesel fuels. The Russian Oil Act permitted the President to lift the import prohibition by certifying to Congress that Russia has fulfilled certain obligations relating to regional security and Ukrainian sovereignty. The Russian Oil Act also required the President to first consult with specified committees of the US House of Representatives and the US Senate and deliver a report to Congress justifying the President’s basis for the certification prior to the certification’s submission. Shortly after GL 135’s publication, at least one US representative and several senators have published statements of disapproval, noting that the President has not satisfied the conditions necessary to lift the prohibitions set forth in the Act and that GL 135 therefore violates the law.

Shortly after the passage of the Russian Oil Act, the US, its Group of Seven (G7) allies, the European Union (EU), and Australia (collectively, the Price Cap Coalition) in December 2022 entered into an agreement to prohibit the import of crude oil and petroleum products of Russian origin at or below a certain price (the price cap). The Price Cap Coalition also agreed to limit certain services related to maritime transport of such Russian-origin products. In 2025, the US further limited the ability of US persons to provide petroleum services to Russian persons, but continued to permit certain maritime transport services previously authorized under the price cap.

GL 135 also follows the recent passage of the Lindsey Graham Sanctioning Russia and Iran Act of 2026 (Lindsey Graham Act). The Lindsey Graham Act (discussed in detail in our article here) directed the President to impose new sanctions and tariffs targeting the Russian energy sector, among other things. Generally, this legislation was intended to further isolate the Russian economy and increase pressure on the country to wind down its actions in Ukraine. The Lindsey Graham Act, however, also provided the President with significant discretion regarding its implementation. 

Key Takeaways

Deal & Legal Uncertainty. The details of the “diesel deal” announced by President Trump on social media have not been publicized in any official format or confirmed by Russia, but the GL appears to be the Administration’s first step toward its fulfilment. As discussed, above, however, GL 135 sits in tension with the Russian Oil Act and may therefore be subject to legal challenge. Further, as discussed in our series of articles on General License X, general licenses previously issued under other sanctions regimes as negotiating tools were quickly withdrawn when negotiations broke down.

Impact on Lindsey Graham Act sanctions. As noted in our prior article, the significant discretion reserved to the President by the Lindsey Graham Act raised questions about how aggressively the legislation would be enforced. The issuance of GL 135 so soon after the passage of the Lindsey Graham Act enhances the possibility that the President may exercise his discretion not to impose certain of the energy-sector-related sanctions and/or tariffs dictated by that legislation.

EU & UK Restrictions Remain in Place. GL 135 does not affect Russia-related sanctions imposed by other members of the Price Cap Coalition, such as the UK and EU.  The UK’s sanctions prohibiting the supply and delivery by ship of Russian diesel and the EU’s analogue prohibiting the trading, brokering and transport of Russian diesel, remain in force. Consequently, UK and EU based traders, shipowners, charterers, and financial services providers (such as banks and insurers) will be prohibited from engaging in or providing financial assistance for the supply and delivery of Russian diesel into the US unless it is price cap compliant. Moreover, the UK and EU designations of many Russian producers are still in force and will prohibit the involvement of UK and EU persons with such designated persons irrespective of price cap compliance.

Plan Ahead & Monitor for Updates. Companies may wish to evaluate their risk tolerance before taking actions pursuant to GL 135 and should consider planning for contingencies while monitoring closely for regulatory or legal updates.