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OFAC extends the Lukoil sale talks to November 21st but still does not let a sale close

General License 131K is the eleventh extension in a row. It allows talks and contingent contracts only, and the separate approval a closing needs has not been issued.
Alert analysis
October 28th, 2026
Vektora
Alert typeMarket-Relevant Uncertainty
Closing of a saleNot authorized
Buyer terms publishedNone
Sources9 cited
As ofOct 28th, 2026
Next decision
24days, to GL 131K expires on 21 November
As of 28 Oct 2026
21 Nov · 24 daysGL 131K expires24 Apr · 178 daysRetail and Bulgarian licenses endToday
  1. 21 Nov · 24 days GL 131K expires
  2. 24 Apr · 178 days Retail and Bulgarian licenses end

Source: US Treasury, Office of Foreign Assets Control, October 21st, 20261

Day counts are worked out from today's date when the page opens.

Executive Summary

The US Treasury has given buyers of Lukoil's foreign assets until November 21st, 2026 to negotiate, and it still does not let a sale close. The Office of Foreign Assets Control (OFAC) issued General License (GL) 131K on October 21st, 2026, one day before GL 131J would have expired2,3.

The license covers talks and contingent contracts, not completion. Any contract must depend on a separate OFAC authorization. OFAC says that authorization is not part of GL 131K, and it may revoke the license at any time1.

The open question is where a buyer's money would sit. OFAC expects funds owed to Lukoil to be blocked in an account under US jurisdiction1. Carlyle, the last named buyer, confirmed on October 9th that it no longer pursued its deal, and a group led by Todd Boehly is now the leading bidder, according to Fesenko Law Offices3.

Alert type
Market-Relevant Uncertainty
License expires
November 21st, 2026
Extensions in a row
Eleventh
Closing authorized
No
01Risk Matrix

The legal and investment risk sits in the gap between a negotiating license and a closing approval.

LegalMediumContracts must stay contingent on a separate OFAC approval.

OFAC says any contract entered into under GL 131K must expressly depend on a separate authorization, and that the license does not allow the actual sale or transfer of any asset1.

RegulatoryMediumOFAC may revoke the license at any time.

OFAC says it may revoke GL 131K at any time, including if Lukoil and its foreign arm do not appear to negotiate in good faith1.

EconomicLowLukoil's foreign businesses keep trading under license.

Ordinary-course transactions are authorized, with one condition: no funds may go to a person or account in Russia4.

ReputationalMediumBuyers face scrutiny of who profits from the sale.

Senators Jeanne Shaheen and Roger Wicker asked Treasury to explain by October 18th how Russian participants would be kept from benefiting, and Fesenko Law Offices found no public answer3.

InvestmentMediumNo buyer has a closing path that OFAC has approved.

Carlyle's January 2026 agreement lapsed at the end of July without OFAC approval, and it confirmed on October 9th that it was no longer pursuing the deal3,5.

02Forecast Watch

The likeliest next step is another short extension, and a closing approval inside the window is the less likely call.

Confidence on the mechanism is high: OFAC's own license and FAQ set out what is and is not allowed1. Confidence on the horizon is medium, because the decision belongs to OFAC and to the White House, and neither has published a timetable. The three calls below are independent, so their probabilities do not sum to one.

Analyst assessment. Each call is scored once its date passes.

80%

OFAC publishes a general license that extends or replaces GL 131K, shown on its Recent Actions page.

Settles Nov 21st, 202624 days left
35%

Lukoil, a buyer or Reuters reports that a contingent contract for the sale of Lukoil International GmbH has been signed.

Settles Nov 21st, 202624 days left
10%

OFAC or a party to the sale publicly confirms that OFAC has authorized a sale of Lukoil International GmbH to close.

Settles Dec 31st, 202664 days left
  • OFAC Recent Actions page: new Russia-related general licenses, checked on the days it publishes.
  • OFAC FAQs 1224 and 1225: any change to the conditions for a sale.
  • Lukoil International GmbH disclosures: any statement on the talks.
  • Treasury's reply to Senators Shaheen and Wicker, if one is published.
03The Signal

The license text did not change; only the dates did.

GL 131K replaced GL 131J on October 21st, 2026, and extends the authorization through November 21st2. OFAC also amended two Russia-related FAQs6. Apart from the license number and dates, nothing in them changed, according to Fesenko Law Offices3. The conditions OFAC set for approving a sale read the same as they did in September3.

Authorized: negotiations, due diligence and contingent contracts. Not authorized: the sale, any transfer of shares or assets, or any transfer of funds to a person or account in Russia1,3. The ban on sending funds to Russia has been in the series since GL 131A, issued on December 10th, 20257.

The licenses in the series have each run between 29 and 45 days up to GL 131H8.

Fig. 1

Days each Series 131 license ran

From the issue date to its expiry date

020406029GL 131GL 131AGL 131BGL 131CGL 131DGL 131EGL 131FGL 131GGL 131H

Source: Fesenko Law Offices, July 24th, 20268

04What Happened

Since the October 2025 sanctions, no named buyer has had OFAC's approval to close.

October 22nd, 2025
Sanctions.
OFAC adds Lukoil to its sanctions list, together with over 30 subsidiaries of Lukoil and Rosneft1,9,5.
January 2026
Announcement.
Lukoil agrees to sell Lukoil International GmbH to the US firm Carlyle3,5.
End of July 2026
Other.
The Carlyle agreement lapses without OFAC approval3,5.
September 30th, 2026
Talks.
Lukoil International GmbH says it is negotiating with other interested parties5.
October 9th, 2026
Other.
Carlyle confirms it is no longer pursuing the deal3.
October 21st, 2026
Other.
Latest. OFAC issues GL 131K, extending the negotiating window to November 21st2.
Woodcut portrait of Todd BoehlyUnited States

Todd Boehly

Investor leading the bid

Fesenko Law Offices calls his group the leading bidder for Lukoil International GmbH3.

What to watch
  • A signed contingent contract with published terms.
  • Where the purchase money would sit.

Portraits after photographs. Todd Boehly: Eric van den Brulle, via Wikimedia Commons, CC BY-SA 4.0.

The New York Times reported, as relayed by Fesenko Law Offices, that investors from the United Arab Emirates and Qatar would own more than half of the equity3. The Financial Times said the US International Development Finance Corporation (DFC) would take a stake of about 15 percent5.

05What's Being Overstated

A signing has been predicted before, and the record does not show one.

  • A signing is near. The New York Post reported on October 9th that the DFC expected to sign within two weeks. Two weeks have passed with no signing3.
  • The extension signals progress. GL 131K carries over the terms of GL 131J, and OFAC has issued a new license each time the old one neared expiry4,3. That shows OFAC keeps the option open. It does not show a buyer is close.
  • The license lets the parties close. It lets them agree on a deal. Funds owed to Lukoil must still be blocked in an account under US jurisdiction until sanctions are lifted, and Russian officials reportedly doubt Washington would ever release them1,3.
06Why It Matters

Lukoil's foreign refineries, trading and upstream assets run on one license that expires in weeks.

Lukoil's retail stations outside Russia and its Bulgarian entities, including the Burgas refinery, are covered by GL 128D and GL 130B until April 24th, 2027. Everything else, including the Romanian refinery, the stake in the Dutch refinery, trading and upstream, depends on GL 131K alone, according to Fesenko Law Offices3. Interfax, a Russian news agency, put the value of the foreign assets Lukoil wants to sell at $20 billion5.

OFAC's FAQ 1225 says non-US persons generally do not risk US sanctions exposure for transactions the license authorizes4. For suppliers, lenders and landlords of these businesses, the date that matters is November 21st3.

07Sector Impact

The exposure is greatest for refiners and traders, and smallest for fuel retail.

MixedConditional

Refining and trading

The Romanian refinery, the Dutch refinery stake, trading and upstream depend on GL 131K alone3.

Conditional: Exposed if the license lapses

Fuel retail

Retail stations outside Russia are licensed until April 24th, 20274.

Mixed: Covered for six months

Banks and payment processors

They may debit and credit the accounts of the relevant entities, but may not send funds to Russia4.

Conditional: Workable with controls on Russian payments
08Client Implications

Plan around the November 21st date, not around an unsigned deal.

  • Private equity and venture capital firms: a bid is a contingent contract until OFAC approves a closing. Price the time and the approval risk1.
  • Family offices: exposure to Lukoil's foreign assets rests on a license OFAC may revoke at any time1.
  • Corporates: test each payment against the license. Is it ordinary operations, and does any money reach Russia3?
  • Law firms: contracts with Lukoil's foreign entities should say what happens if the license is not renewed on November 21st3.
09Due Diligence Questions

Five questions separate a live bid from a stalled one.

  • Approval: Has the buyer asked OFAC for the separate authorization, and what has OFAC said?
  • Funds: In which account would the purchase price sit, and is it under US jurisdiction1?
  • Windfall: Does the structure give Lukoil up-front value, including through asset or share swaps1?
  • Payments: Can the counterparty show that no payment reaches a person or account in Russia4?
  • Resale: Is the buyer prepared to seek OFAC review before selling on material assets1?
10Vektora Assessment

The extension keeps talks alive. It does not show a buyer has OFAC's approval.

Confidence: medium. The license terms are primary documents, which gives high confidence on what is allowed. The state of the talks rests on press reports relayed by law firms and by Interfax, which gives medium confidence.

Our primary assessment: OFAC will most likely issue another short extension before November 21st, and no closing will be approved inside this window. OFAC has extended each license in the series so far4,3.

The strongest alternative reading is that the Boehly group has the White House behind it and a signing is close. Fesenko Law Offices reports that key decisions on Lukoil are being made at the White House and that the sale is folded into the Ukraine negotiations3. That would make a faster approval possible. What would make our call wrong: a public OFAC authorization for a closing, or a signed contract with published terms.

11Sources
  1. FAQ 1224: What negotiations does Russia-related General License 131K authorize? US Treasury, Office of Foreign Assets Control, October 21st, 2026
  2. Sanctions Update: October 26, 2026. Steptoe, October 26th, 2026
  3. OFAC GL 131K: One More Month for the Lukoil Deal, No New Conditions. Fesenko Law Offices, October 23rd, 2026
  4. FAQ 1225: What activities do Russia-related General License 128D and General License 131K authorize related to Lukoil International GmbH (LIG)? US Treasury, Office of Foreign Assets Control, October 21st, 2026
  5. U.S. OFAC extends Lukoil's license to sell foreign assets until Nov 21. Interfax, October 21st, 2026
  6. Recent news from Treasury's Office of Foreign Assets Control: Oct. 26. ABA Banking Journal, October 26th, 2026
  7. OFAC Amends General Licenses for Certain Categories of Transactions Involving Lukoil Entities Outside of Russia. Baker McKenzie, December 12th, 2025
  8. OFAC GL 131H: Eighth Extension in a Row Gives Lukoil International GmbH Deal Until August 22. Fesenko Law Offices, July 24th, 2026
  9. OFAC General Licenses Open Door for Lukoil Divestment and Other Limited Activities. Cleary Gottlieb, November 20th, 2025