What does the US Russian diesel licence mean for maritime sanctions compliance?

Marina Lebedeva
Senior Analyst, Infospectrum
October 12, 2026

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The US Department of the Treasury has authorised certain transactions involving Russian diesel. But that does not give every vessel, operator or service provider permission to participate. Here is what has changed, what remains restricted and what businesses should check next (correct as of 12 October 2026).

The US decision to license transactions involving Russian-origin diesel raises a practical question for maritime businesses: can they now transport, insure or service the vessels carrying it?

The answer depends on more than the cargo. The scope of the US authorisation, the sanctions applicable to the parties involved and the rules governing each service all matter. Crucially, a US licence does not change EU restrictions on Russian petroleum products or listed vessels.  

What has the US authorised?

On 9 October 2026, the US Treasury’s Office of Foreign Assets Control (OFAC) issued General License 135. It authorises transactions otherwise prohibited under two specified Russia-related sanctions regulations where they relate to the sale, delivery, offloading or importation of Russian-origin diesel, including importation into the United States. The authorisation runs until 12:01 a.m. EDT on 7 April 2027.   

There is an explicit financial limitation: the licence does not authorise debits to accounts held at US financial institutions by Russia’s central bank, National Wealth Fund or Ministry of Finance.  

The licence covers only transactions under 31 CFR parts 587 and 589. It says nothing on blocked vessels, services such as bunkering, or the price cap. Other OFAC and US statutory restrictions may still apply.  

For businesses considering a transaction, the starting point should therefore be the licence’s precise scope, rather than the broader announcement of renewed diesel supplies.

Can Russian diesel now be imported into the US?  

The licence authorises importation under the OFAC regulations, but does not address the 2022 Ending Importation of Russian Oil Act, which bans Russian diesel imports. The September 2026 Sanctioning Russia and Iran Act also directs the President to raise duties by up to 500 percent, on Russian petroleum products, due around 18 October on our count. It will take some time to clarify how these apply.

Does the US licence change EU sanctions?

No. The US authorisation does not amend EU rules. EU restrictions on transporting Russian petroleum products to third countries and providing related services remain a separate consideration.  

The EU price cap for premium-to-crude petroleum products, including diesel, is USD 100 per barrel. EU operators may provide maritime transport and related services only where the relevant price-cap conditions are met. This is distinct from the EU’s ban on importing Russian oil and refined petroleum products.  

Vessel-specific restrictions also matter. Article 3s of Regulation 833/2014 prohibits specified services to vessels listed in Annex XLII, including bunkering, ship supply, crew changes, fendering and tug services. Cargo authorisation under US rules does not remove those EU restrictions.  

Permission to trade the cargo is not the same as permission to serve the vessel.

What does this mean for bunker suppliers?

The main risk is Article 3m(2) of Regulation 833/2014, which prohibits services related to the transfer of Russian petroleum products. The European Commission guidance puts bunkering outside the price cap but allows it in EU ports only if the cargo was bought at or below the cap and is bound for a third country. The guidance is not law. Listed vessels cannot be bunkered at all (Article 3s).

What about owners, operators and managers?

They may carry Russian diesel only at or below USD 100 per barrel. A vessel that carried product bought above the cap, where the operator knew or had reasonable cause to suspect it, loses EU services for 90 days (Article 3n(7)).

What should maritime businesses check next?

The following questions provide a useful starting point for a transaction-specific compliance review:

Does the US licence cover the proposed activity? Check the relevant sanctions authorities, licence conditions and expiry, rather than assuming every diesel-related transaction is authorised.  

Which other jurisdictions apply? Consider the parties providing transport, insurance, finance and marine services.  EU restrictions can apply to EU companies and nationals operating outside the Union.  

What is the vessel’s sanctions exposure? Review the vessel alongside its ownership and operating relationships, rather than assessing the cargo in isolation.

Is the cargo documentation sufficient? Where price-cap rules apply, review the relevant attestations and supporting cost information.  

What needs specialist clarification? Escalate uncertainty about overlapping sanctions, import requirements or service restrictions before committing to the transaction.

A licence changes the rules, not the need for due diligence

The central distinction is straightforward: a transaction authorised under one sanctions framework may still face restrictions under another. General License 135 creates permission within specified US regulations; it does not provide universal clearance for the cargo, vessel and services involved.  

For maritime businesses, the next step is not simply to ask whether Russian diesel can move. It is to establish whether their role in a particular movement is permitted, and what evidence supports that decision.

Build a clearer picture of maritime sanctions exposure

Seasearcher Advanced Compliance brings together sanctions screening, ownership intelligence, cargo exposure and vessel behaviour in one investigative workflow. Continuous monitoring and audit-ready reporting help compliance teams investigate risk and document the basis for their decisions. Learn more: Explore Seasearcher Advanced Compliance

This article provides general information, not legal advice. You should obtain transaction-specific advice and check the latest applicable regulations and guidance before acting.

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