OFAC GL 131K authorizes LIG negotiations—not sale closing

Put a hard gate between contingent agreement and closing

The direct control is a transaction-stage ledger. Preserve the parties and ownership basis, covered LIG entity or asset, proposed buyer, advisers, scope of diligence, agreement type, draft and signed versions, GL 131K reliance analysis, license issue and expiration times, prohibited-party checks, payment and blocked-account treatment, conditions precedent, separate-license request, OFAC correspondence, approver, and current state. Negotiating or signing a contingent instrument does not establish authority to transfer the asset or consideration. ^{[1] [2]}

The contract record should make the separate-authorization condition explicit and machine-visible. A workflow that recognizes only unsigned and signed can release closing tasks too early. Use at least diligence authorized, contingent agreement under review, contingent agreement executed, separate authorization requested, separate authorization granted or denied, conditions satisfied, closing approved, and completed. Each state needs its own evidence, accountable owner, and expiry handling. ^{[1] [2]}

Separate authorized activity by purpose and time

GL 131K covers more than one operating purpose. Paragraph (a) addresses negotiation and entry into contingent contracts. Paragraph (b) addresses specified maintenance or wind-down of operations, contracts, or other agreements of covered LIG entities, and paragraph (c) addresses use of blocked accounts for paragraph (b) transactions. Those permissions should not collapse into one active-license flag because an activity authorized for maintenance may not authorize a sale step, new transaction, or payment outside the stated terms. ^[1]

The time control is equally specific. The license states 12:01 a.m. Eastern Standard Time on November 21, 2026, and says GL 131K replaced GL 131J effective October 21. Preserve the relied-on license version, activity time, time zone, amendment or supersession event, and work remaining at expiry. An approval based on an older license or an activity completed after the relevant window requires renewed analysis rather than retrospective relabeling. ^[1]

Treat FAQ factors as future-license review inputs

FAQ 1224 says OFAC would evaluate a proposed sale using factors tied to U.S. national-security and foreign-policy objectives. It identifies expected transaction conditions including severing LIG ties with Lukoil, blocking funds owed to Lukoil in an account subject to U.S. jurisdiction until sanctions are lifted, avoiding a windfall such as upfront value, and possible OFAC review before later divestment of material LIG assets. These are material diligence and drafting inputs, but the FAQ is not the separate authorization required to close a particular sale. ^[2]

A license-request package should map each stated factor to proposed terms, evidence, unresolved issues, responsible reviewer, and later covenant monitoring. It should also preserve the complete current sanctions analysis, excluded transactions, other blocked persons, funds destination, ownership and control, and transaction nexus. Meeting a checklist assembled from the FAQ does not itself establish that OFAC will issue a license or that another authority permits the transaction. ^{[2] [1]}

Test a deal that crosses the license boundary

A representative evaluation should open a controlled LIG divestment scenario, conduct diligence, negotiate terms, sign an expressly contingent agreement, request separate authorization, and prevent transfer, release of consideration, and closing until the required evidence is present. Add a majority-owned subsidiary, a non-covered blocked person, a payment proposed to a Russian account, a maintenance invoice, a changed buyer, an amended contract, an expiry during review, and a superseding OFAC license. Reviewers should reproduce why each action was permitted, held, escalated, or rejected.

The October 21 action, GL 131K, and FAQ 1224 establish the cited authorization, timing, contingent-contract condition, maintenance scope, exclusions, and stated future-license factors. They do not determine the ownership, nexus, license coverage, contractual sufficiency, sanctions status, permissibility, or outcome of a particular asset, entity, buyer, payment, agreement, or closing. Current primary authorities, transaction facts, and qualified sanctions and legal review remain necessary. ^{[3] [1] [2]}

Limitations and unknowns

• No LIG entity, asset, proposed buyer, ownership chain, contract, payment, blocked account, license application, OFAC communication, transfer, or closing was reviewed.
• The public sources do not establish whether OFAC will grant separate authorization for any proposed transaction or which additional conditions it may impose.
• The complete applicability of U.S. and non-U.S. sanctions, export controls, investment review, competition, tax, corporate, and other requirements remains transaction-specific.

Enterprise buyer test

Translate this change into the exact population, record type, workflow stage, decision owner, effective date, and evidence that could be affected. Ask current or prospective providers to demonstrate the named workflow with representative data and an exception—not a polished feature tour. Record what official documentation establishes, what a provider states, what the team observes, and what remains unresolved.

A defensible review also identifies the dependency outside the product. Authority interpretation, policy configuration, data quality, integrations, human judgment, approval rights, release governance, training, and retained evidence may remain customer or service responsibilities. The evaluation should preserve those boundaries instead of treating a technology claim as the complete operating model.

What we will watch next

Trade Controls Brief will watch the named source and affected market records for later evidence that changes status, scope, availability, implementation timing, workflow consequence, or the limits of the initial report. A later announcement does not silently overwrite this dated account; the change ledger preserves the sequence.