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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On April 14, 2026, the Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) amended two general licenses to continue authorizing limited transactions under previous sanctions involving Russia&rsquo;s&nbsp;Lukoil operations.
<a href="https://ofac.treasury.gov/media/935496/download?inline">Russia-related General License 128C</a>, &ldquo;Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia.&rdquo;&nbsp;This amended general license extends until October 29, 2026, all transactions that are ordinarily incident and necessary to the purchase of goods and services from, or the maintenance, operation, or wind down of Lukoil retail service stations located outside of Russia.
<a href="https://ofac.treasury.gov/media/935501/download?inline">Russia-related General License 130A</a>, &ldquo;Authorizing Transactions Involving Certain Lukoil Entities in Bulgaria.&rdquo;&nbsp; This amended general license authorizes until October 29, 2026, transactions with four Lukoil entities incorporated in Bulgaria, and any entity in which such entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
Certain transactions otherwise prohibited by the Russia Harmful Foreign Activities Sanctions regulations remain unauthorized and, therefore, each of these general licenses requires close analysis.&nbsp; For additional background information on the sanctions against Lukoil, see Thompson Hine Updates of&nbsp;<a href="https://www.thompsonhinesmartrade.com/2025/10/ofac-sanctions-russias-two-largest-oil-companies/">October 23, 2025</a> and <a href="https://www.thompsonhinesmartrade.com/2025/11/ofac-issues-new-and-amended-russia-related-general-licenses/">November 17, 2025</a>.

OFAC Amends Russia General Licenses Related to Lukoil

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