OFAC General License 135 and Russian Diesel: What Procurement and Sanctions Teams Need to Know

A temporary license, a permanent set of questions

Few procurement decisions mix geopolitics, compliance and commodity risk as tightly as buying fuel linked to a sanctioned country. On October 9, 2026, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 135, titled “Authorizing Transactions Related to the Sale, Delivery, Offloading, and Importation of Diesel Fuel of Russian Federation Origin.” The same day, President Donald Trump said Russia had agreed to supply diesel to U.S. and global markets.

Coverage from the BBC, CNN, Reuters, the Financial Times, The Guardian, Forbes and Newsweek framed the move in political and market terms. For procurement and supply-chain teams the questions are more practical: What exactly is allowed? What is not? How likely is it that real barrels arrive? And what should you change in your sourcing and compliance workflows this week?

What the license says

Based on the published description:

• Scope. It authorizes transactions that would otherwise be prohibited under the relevant Russia-related sanctions regulations, specifically the sale, delivery, offloading and importation of diesel fuel of Russian Federation origin, including importation into the United States.
• Expiry. The authorization runs through 12:01 a.m. eastern daylight time on April 7, 2027.
• Key exclusion. It does not authorize debits to accounts at U.S. financial institutions held by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.
• Nature. It is a temporary general license, not a repeal of sanctions. Activity outside its terms remains prohibited, and the underlying sanctions framework stays in place.

A general license can be amended, narrowed or revoked. Anyone building contracts around it should assume the authorization may not last the full term.

What the administration announced

President Trump said he had concluded a discussion with Russian President Vladimir Putin in which Russia agreed to supply diesel. The volumes he cited were: more than 300,000 metric tons immediately; a further 500,000 metric tons in November; 1 million metric tons immediately thereafter; and a potential additional 3 million metric tons depending on the condition of Russian diesel refineries.

Those are political announcements, not contracts or shipping schedules. The last tranche is explicitly conditional on refinery condition, a caveat that matters because Russian refining capacity has been under pressure.

Market and political reaction

Reaction was sharply divided.

Ukraine’s position. Reporting from the BBC and Radio Free Europe/Radio Liberty said Ukrainian President Zelensky called the arrangement a gift to Putin. Hromadske and Euromaidan Press framed the license as Washington making official the sale of Russian diesel blocked by sanctions. Newsweek reported that Ukraine struck a major Russian oil hub hours after the announcement, and other outlets tied the diesel story to the broader dispute over Ukrainian strikes on Russian refineries and an earlier discussion of an energy ceasefire.

Allied reaction. CNN described the deal as driving a wedge through the Western alliance, reflecting concern in Europe that U.S. sanctions relief undermines coordinated pressure on Moscow.

Price expectations. The Guardian quoted experts saying the deal would have little impact on U.S. diesel prices, and Forbes ran a skeptical piece arguing the deal does little. Forbes also published analysis noting that some missing barrels were tied to disruption around the Strait of Hormuz rather than only to Ukrainian strikes. Newsweek framed the move as an attempt to bring diesel prices down ahead of midterm elections.

Search interest. Google’s U.S. daily trending list on October 12 was dominated by sports and entertainment, and this story did not appear there. That fits the pattern: attention comes from commodity buyers, trade compliance staff and energy analysts, who search for license text and counterparty guidance rather than headlines.

Why announced volumes may not equal delivered volumes

Procurement teams should be careful about taking the headline numbers at face value.

1. Refinery capacity. The conditional 3 million tons shows even the administration acknowledged uncertainty about Russian refining.
2. Logistics. Shipping, port handling, insurance and vessel availability all take time to organize. Ships and cargo owners that avoided Russian trade must re-engage.
3. Financial plumbing. The exclusion for central bank, National Wealth Fund and Finance Ministry accounts narrows how some payments may flow. Banks may remain cautious regardless of the license.
4. Conflict risk. Ongoing strikes on refineries and energy infrastructure can interrupt supply without warning.
5. Political risk. A license issued by executive action can change quickly with events, diplomacy or Congress.

The sensible planning assumption is that physical supply may ramp slowly and unevenly, and that price effects will depend on global balances, not on one bilateral announcement.

Practical steps for procurement teams

1. Update sanctions screening rules

Confirm that your screening tools reflect GL 135 correctly. Over-blocking can stop legitimate transactions, while under-blocking can create violations if a transaction falls outside the license. Document your rules and who approved them.

2. Determine whether you intend to buy at all

Some companies will decide, for reputational, lender, customer or ESG reasons, not to buy Russian-origin diesel even though it is now lawful for U.S. persons under the license. Others have contractual commitments, such as supplier codes of conduct or financing covenants, that prohibit it. Decide this at the policy level, not deal by deal.

3. Check scope and exclusions before every deal

Confirm that the product is diesel of Russian Federation origin as defined, that every party and vessel is screened, and that no payment touches the excluded Russian state accounts. Keep a file that shows the analysis.

4. Verify counterparties and origin

Blending, ship-to-ship transfers and re-labeling are known sanctions-evasion techniques. Require origin documentation, review vessel histories and use enhanced due diligence on intermediaries that are new to you.

5. Talk to banks, insurers and carriers

Your bank may have its own risk appetite stricter than the license. Insurers and shipping lines may require additional assurances. Clarify this early to avoid stranded cargoes.

6. Model price and supply scenarios

Build scenarios in which Russian volumes are large, small or interrupted. Tie fuel-surcharge clauses and hedging strategies to market indices rather than assumptions about this policy.

7. Watch non-U.S. rules

GL 135 is a U.S. authorization. The European Union, the United Kingdom and other jurisdictions maintain their own sanctions, and a multinational group must comply with all that apply. A U.S. license does not authorize activity prohibited elsewhere.

Who is most affected

• Fuel buyers and distributors that purchase diesel in volume.
• Trucking, rail, shipping and logistics operators whose costs follow diesel prices.
• Agricultural and construction firms, which are heavy diesel users, particularly in seasonal peaks.
• Commodity traders and banks, which must manage legal risk and financing.
• Multinationals with operations in jurisdictions that maintain stricter sanctions.

Risks to keep on the register

• Reversal risk. The license could be revoked or amended.
• Secondary and parallel sanctions risk. Non-U.S. regimes and counterparties may treat participants differently.
• Reputational risk. Customers, employees and investors may react to sourcing from Russia.
• Operational risk. Quality specifications, contamination and documentation issues are more common with unfamiliar supply chains.
• Financing risk. Lenders and insurers can add conditions at any point.

Frequently asked questions

What is General License 135? An OFAC authorization allowing transactions related to the sale, delivery, offloading and importation of Russian-origin diesel, including into the U.S.

When does it expire? At 12:01 a.m. EDT on April 7, 2027.

Does it lift Russia sanctions? No. It is a limited, temporary authorization with exclusions.

Will it lower diesel prices? Experts quoted in the press expect little near-term effect, though actual outcomes depend on delivered volumes and global market conditions.

Do I have to buy Russian diesel? No. The license permits specific transactions; it does not require anyone to buy.

Bottom line

General License 135 is best read as a dated compliance change, not a supply guarantee. For procurement teams the right posture is disciplined: update screening, set a clear internal policy, scrutinize origin and counterparties, and plan on the basis of delivered barrels rather than announced tonnage.

This article summarizes public announcements and press reports and is not legal, sanctions or tax advice. Confirm the current license language and consult counsel before any transaction involving Russian-origin diesel.

Sources consulted: U.S. Treasury/OFAC announcement as reported by the press, BBC, CNN, Reuters, Financial Times, The Guardian, Forbes, Newsweek, Radio Free Europe/Radio Liberty, Euromaidan Press, Hromadske and Google Trends (US daily trending searches, October 12, 2026).