OFAC Russia General Licenses 55F and 115D Explained

OFAC Russia general licenses 55F and 115D give energy, financial, and trade compliance teams a defined but narrow path for certain Russia-related activity. Both authorizations expire at 12:01 a.m. eastern standard time on December 18, 2026, making transaction-level scoping, payment screening, and contingency planning immediate priorities.

What General License 55F Authorizes for Sakhalin-2

General License 55F authorizes specified transactions connected to the Sakhalin-2 project that would otherwise be prohibited under the Russian Harmful Foreign Activities Sanctions Regulations. Issued on June 11, 2026, the license replaces General License 55E and continues a limited authorization for defined energy activities involving Russia and Japan.

A general license does not remove a party or project from sanctions. It permits transactions that fit its language while leaving other prohibitions in force. Companies relying on GL 55F therefore need documented evidence connecting each shipment, service, payment, and counterparty to an authorized activity.

Japan-Only Sakhalin-2 Transactions

GL 55F covers three principal categories:

• Transactions involving the maritime transport of Russian-origin crude oil connected to Sakhalin-2 byproduct, provided the activity is solely for importation into Japan.
• Transactions involving Gazprombank or entities it owns 50 percent or more that relate to the Sakhalin-2 project, including transactions involving Sakhalin Energy LLC.
• Transactions otherwise prohibited under the January 10, 2025 petroleum services determination, provided they relate to Sakhalin-2.

The Japan-only condition is particularly important. Trade routes, cargo ownership, contractual destinations, transshipment arrangements, and documentary instructions should consistently support importation into Japan. A transaction should not be treated as authorized merely because the product originated from Sakhalin-2.

GL 55F also does not authorize transactions prohibited by Directive 2 or Directive 4 under Executive Order 14024. Nor does it authorize dealings involving other blocked persons when no separate authorization applies. Screening must consequently extend beyond the project name to vessels, owners, operators, banks, intermediaries, insurers, and entities captured through the 50 percent ownership rule.

How General License 115D Applies to Civil Nuclear Energy

General License 115D provides a separate authorization for certain transactions related to civil nuclear energy. It permits otherwise prohibited dealings involving specified Russian financial institutions, their 50 percent owned entities, and the Central Bank of the Russian Federation when the transactions fall within the license's defined civil nuclear scope.

Covered institutions include Gazprombank, Vnesheconombank, Otkritie, Sovcombank, Sberbank, VTB, Alfa-Bank, Rosbank, Bank Zenit, Bank Saint-Petersburg, and the National Clearing Center. The license does not create an unrestricted channel for transactions with these institutions. The underlying activity must remain eligible throughout the transaction lifecycle.

The Project Initiation Cutoff

For GL 115D, activity is related to civil nuclear energy only when it is conducted solely to maintain or support a civil nuclear project initiated before November 21, 2024. That limitation requires more than a general connection to the nuclear industry.

Compliance teams should typically retain contracts, project approvals, purchase orders, technical records, board materials, and other evidence demonstrating when the project began. Amendments, expansions, replacement scopes, and new phases require careful review because they may not necessarily qualify as maintenance or support for the original project.

The authorization also contains significant payment restrictions. It does not permit opening or maintaining correspondent accounts or payable-through accounts for entities subject to Directive 2. It likewise does not authorize debits to U.S. accounts of the Central Bank of Russia, the National Wealth Fund of the Russian Federation, or the Russian Ministry of Finance.

Payment routing through an intermediary does not cure an otherwise prohibited transaction. Banks and corporate compliance teams should evaluate the full payment chain, including originators, beneficiaries, correspondents, account locations, and ownership relationships.

Compliance Priorities Before the December 18 Deadline

Both GL 55F and GL 115D expire at 12:01 a.m. eastern standard time on December 18, 2026. Businesses should not assume that either authorization will be renewed, replaced, or extended. A license expiration can affect pending invoices, cargoes in transit, scheduled services, and payments initiated before the deadline but completed afterward.

Build a Transaction-Level Reliance File

A defensible sanctions process should connect every transaction to the exact language of the applicable general license. The file should generally identify:

1. The activity that would otherwise be prohibited.
2. The specific authorization relied upon.
3. The parties, banks, vessels, and intermediaries involved.
4. The ownership analysis for relevant entities.
5. The qualifying destination, project date, or civil nuclear purpose.
6. The expected completion date before license expiration.

GL 55F files should document the Sakhalin-2 connection and, where applicable, the exclusive importation of byproduct oil into Japan. GL 115D files should demonstrate that the activity solely maintains or supports a civil nuclear project initiated before November 21, 2024.

Screen the Entire Commercial and Payment Chain

Name screening alone is generally insufficient. Compliance teams should evaluate entities owned 50 percent or more by designated persons, payment instructions, correspondent banks, vessel ownership, insurers, freight providers, and contractual counterparties. Directive 2 and Directive 4 restrictions remain relevant even when a transaction appears to fit the broader commercial purpose of a license.

Organizations should also establish escalation procedures for activity expected to remain incomplete near December 18. Options may include accelerating eligible performance, restructuring a payment through lawful channels, seeking specific authorization, or suspending activity. Any restructuring should reflect genuine commercial substance and should not be used to evade sanctions.

OFAC sanctions compliance remains separate from customs duty and duty drawback law. Export activity that supports a drawback claim does not receive an exemption from sanctions screening. Customs brokers and exporters should continue screening counterparties, financial institutions, carriers, and other transaction participants even when the export is independently eligible for drawback treatment.

Frequently Asked Questions

When Do General Licenses 55F and 115D Expire?

Both licenses expire at 12:01 a.m. eastern standard time on December 18, 2026. Businesses should evaluate when performance and payment will be completed, not simply when a contract, shipment, or payment instruction is initiated. Unless OFAC takes further action, transactions requiring authorization may no longer proceed after expiration.

Does GL 55F Authorize Every Sakhalin-2 Transaction?

No. GL 55F authorizes only defined transactions associated with Sakhalin-2. The maritime transport authorization for Russian-origin byproduct oil is limited to activity solely for importation into Japan. Directive 2, Directive 4, and restrictions involving other blocked persons can still apply.

What Civil Nuclear Projects Qualify Under GL 115D?

The license applies to transactions solely supporting or maintaining civil nuclear projects initiated before November 21, 2024. A project established after that date generally falls outside the authorization. Material expansions or new project phases may also require additional analysis, even when connected to an older facility or commercial relationship.

Are Payments Through Listed Russian Banks Automatically Permitted?

No. A listed bank's inclusion in GL 115D does not authorize every transaction involving that institution. The payment must support qualifying civil nuclear activity, comply with the project cutoff, and avoid excluded account activity. The complete payment chain should be reviewed before funds move.

Do These General Licenses Override Other Sanctions Restrictions?

No. General licenses are interpreted according to their specific scope and conditions. They generally do not override unrelated prohibitions, restrictions involving noncovered blocked persons, or requirements imposed under other sanctions programs. Separate authorization may be required when a transaction falls outside the license language.

Do GL 55F or GL 115D Change Duty Drawback Eligibility?

No direct customs duty or drawback consequence arises from these licenses. Sanctions authorization and drawback eligibility are separate legal analyses. An exporter may have a valid drawback opportunity while still needing to screen the transaction's parties, banks, vessels, and destination-related activity for sanctions compliance.

How Stable Software Can Help

Connect Sanctions Controls With Customs Workflows

Stable Software supports customs brokers through DrawbackAI, flat-license duty drawback software that brokers can white-label for importer clients and use to file under their own filer codes. Stable Software charges a flat software license and never takes a percentage of the refund.

Sanctions authorization does not replace the need for party and payment-chain diligence, including when exports support drawback claims. Brokers, importers, and compliance leaders evaluating how screening fits into broader trade operations can explore Stable Software's denied party screening platform. A coordinated approach helps organizations keep sanctions decisions distinct from customs eligibility while maintaining consistent transaction records across trade compliance functions.

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