A customer sends you an OFAC licence and asks you to release a payment. The licence mentions Lukoil. So does the screening alert. Is that enough to approve it?
The missing detail is what the payment is for. Permission to negotiate a sale, keep a service station operating and transact with particular Bulgarian companies comes from different authorisations. A familiar company name does not make those permissions interchangeable.
OFAC issued three relevant updates in October 2026: General Licences 128D and 130B on 15 October, and 131K on 21 October. Here is how to read them before relying on one for a transaction.
Reviewed on 25 October 2026. The dates below belong to these versions. Check OFAC's current Russia programme page for replacements before acting.
GL 131K: negotiating a sale is different from completing it
General Licence 131K covers certain negotiations and contingent contracts for the sale, disposition or transfer of Lukoil International GmbH and its defined entities. Contract performance must expressly depend on separate OFAC authorisation. Signing an eligible contingent agreement therefore does not, by itself, permit completion.
The licence also separately permits certain maintenance or wind-down activities. Its deadline is 12:01 a.m. eastern standard time on 21 November 2026. It excludes transfers to people or accounts in Russia and retains restrictions concerning other blocked parties and blocked property, subject to its stated exceptions.
For a deal team, the first question is which stage it has reached: negotiation, an eligible contingent contract, maintenance, or completion. Record the paragraph relied on for that stage. Do not carry a negotiation approval forward as approval to close the sale.
GL 128D: retail service stations outside Russia
General Licence 128D concerns defined Lukoil International entities and activities necessary for purchasing goods or services from, or maintaining, operating or winding down, physical retail service stations outside Russia. It runs through 12:01 a.m. eastern daylight time on 24 April 2027.
It also contains a specific permission concerning blocked accounts used for covered activity. Its exclusions include transfers to people or accounts in Russia, the specified Directive 2 and Directive 4 prohibitions, and otherwise prohibited dealings with other blocked persons unless separately authorised.
An invoice carrying a service-station address is a starting point. Check the contracting entity, the service actually supplied and where the money will go. A different group business or payment route needs its own assessment.
GL 130B: named Bulgarian entities and qualifying subsidiaries
General Licence 130B covers transactions prohibited by Executive Order 14024 involving four named companies: Lukoil Neftohim Burgas JSC, Lukoil Bulgaria EOOD, Lukoil Aviation Bulgaria EOOD and Lukoil Bulgaria Bunker EOOD. Its scope also includes entities meeting the licence's direct or indirect, individual or aggregate 50-percent ownership test.
The deadline is 12:01 a.m. eastern daylight time on 24 April 2027. Other prohibitions remain, including those concerning blocked parties outside its defined scope unless separately authorised.
Match the legal entity and any relevant ownership evidence to the licence. A Bulgarian location or connection to the Lukoil group alone does not establish coverage.
What to put in the transaction file
Avoid an approval note that says only “OFAC licence applies.” A colleague picking up the case tomorrow should be able to follow the reasoning without reconstructing the whole investigation.
| Record | What it should explain |
|---|---|
| Parties | Who is involved, how candidate matches were resolved, and which ownership evidence was reviewed |
| Activity | What is being supplied, signed, paid for or transferred, including the stage of any sale |
| Authority | The licence version, relevant paragraph and why the facts fit its scope |
| Payment route | Origin, destination, intermediaries and any restrictions affecting them |
| Timing | Planned execution time against the exact deadline and named time zone |
| Remaining questions | Other applicable restrictions, missing facts and any separate authorisation needed |
| Approval | Who made the decision, supporting evidence and what changes would require another review |
For example, a proposed acquisition might involve a due-diligence invoice today and a purchase-price payment later. Those are separate activities. An approval for the first should identify its basis and leave the second for assessment when the necessary facts and authorisations are available.
Other applicable regimes also need consideration. An OFAC permission does not establish that a transaction satisfies UK, EU or other requirements relevant to the parties and payment chain. Our OFAC and OFSI article covers the broader governance process, including maintaining a licence register.
Keep the screening result and explain the permission
Do not remove a sanctions match from the record simply because a particular activity may be authorised. Preserve the identity investigation, then document the permission relied on for the proposed transaction.
Checklynx sanctions screening helps teams review supplied parties against configured sources, using clustered results and enriched profiles to compare candidates. That supports the identity review. Reading a licence against the contract, payment instructions and applicable law remains a separate responsibility.
When someone asks for a payment to be released, the useful answer explains which activity is covered, under which version, and on what conditions. If a party, payment route or execution date changes, revisit that answer before proceeding.