Overview
Sanctions are supposed to close doors. On December 17, the U.S. quietly propped two doors back open—again. One is a narrow lane for Sakhalin-2 crude tied to Japan’s imports. The other is a wider financial channel that keeps civil nuclear projects functioning even when the payments run through sanctioned Russian banks.
The hook is the contradiction. Washington wants Russia poorer and weaker, but it also wants Japan’s lights on and reactors worldwide fueled. These general licenses are the compromise: strict, conditional permissions that keep allied energy systems stable without admitting they still depend on Russian molecules—and Russian money plumbing.
Key Indicators
People Involved
Organizations Involved
OFAC writes the rulebook for sanctions—and the exceptions that keep the global economy from snapping.
Treasury uses sanctions to pressure Russia while trying not to shock allied energy systems.
A sanctioned Russian bank that still shows up in carve-outs because it’s embedded in energy and nuclear payments.
The operator at the center of a sanctions exception built to keep Japanese supply steady.
Russia’s gas giant, sitting behind the project that forces Washington into narrow exemptions.
A Japanese stakeholder whose continued involvement makes the U.S. carve-out politically urgent.
Russia’s nuclear heavyweight, whose global footprint makes ‘clean’ sanctions hard.
Timeline
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OFAC extends both carve-outs to June 2026
Rule ChangesGL 55E extends Sakhalin-2 authorizations under Japan-only conditions; GL 115C extends civil nuclear authorizations to June 18, 2026.
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Nuclear sanctions friction goes public in Europe
Rule ChangesA U.S. license related to Hungary’s nuclear project highlights how nuclear carve-outs keep recurring.
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Civil nuclear money channel extended to December 2025
Rule ChangesOFAC issues GL 115B, keeping certain nuclear-related transactions authorized through December 19, 2025.
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GL 55D renews Sakhalin carve-out—briefly
Rule ChangesOFAC extends Sakhalin-2 authorizations to December 19, 2025, including petroleum-services relief tied to the project.
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Petroleum services prohibition takes effect
Rule ChangesThe U.S. petroleum services ban becomes active, tightening the compliance squeeze on Russia-related energy work.
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U.S. escalates: petroleum services ban and nuclear carve-out
Rule ChangesTreasury issues the Petroleum Services Determination and publishes GL 115A for civil nuclear transactions.
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Treasury sanctions Gazprombank—then cushions the blast
Rule ChangesTreasury designates Gazprombank and issues GL 55C to preserve specific Sakhalin-2-related pathways.
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GL 55B extends Japan-only Sakhalin lane
Rule ChangesOFAC replaces GL 55A with GL 55B, authorizing Japan-only imports through June 28, 2025.
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Gazprom-linked buyer takes Shell’s old Sakhalin stake
Money MovesReuters reports a Gazprom unit bought Shell’s former stake in Sakhalin Energy for about $1 billion.
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Sakhalin exception becomes a renewable waiver
Rule ChangesOFAC issues GL 55A, extending the Sakhalin-2 shipping-related exception through June 28, 2024.
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Japan’s stakeholders decide to stay in Sakhalin-2
StatementMitsui says Russia approved its plan to keep ownership in the restructured Sakhalin operator.
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U.S. targets shipping services for Russian crude
Rule ChangesTreasury issues a determination under E.O. 14071 restricting services tied to maritime transport of Russian-origin crude.
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War triggers the sanctions era
Force in PlayRussia invades Ukraine, setting off sweeping U.S. and allied sanctions with energy at the center.
Scenarios
Loopholes Renewed Again: OFAC Rolls the Dates Forward Into 2027
Discussed by: Sanctions lawyers and energy-market watchers tracking repeated GL renewals; Reuters reporting on extensions
If the war grinds on and Japan and other partners still can’t fully replace these supply and payment channels, Treasury will likely extend again near the June 18, 2026 deadline. The most likely path is another time-boxed renewal with the same guardrails: Japan-only for Sakhalin-2 crude byproduct, and “existing civil nuclear only” for nuclear transactions. The pattern is already established: restrict broadly, then carve out the unavoidable.
Carve-Outs Tighten: A New Russia Energy Sanctions Package Shrinks the Exceptions
Discussed by: Bloomberg-reported and Reuters-cited discussions about potential new Russia energy sanctions; European diplomatic consultations
If Washington decides the current pressure isn’t biting—or if diplomatic efforts collapse and the U.S. pivots to a harder energy squeeze—OFAC could narrow these authorizations, add reporting conditions, or let them expire. The trigger would be a deliberate political decision to accept higher allied transition costs (and more short-term market disruption) in exchange for more leverage on Moscow’s revenues and financial channels.
Sanctions-for-Settlement: Energy and Nuclear Relief Becomes a Bargaining Chip
Discussed by: Reuters reporting on preparations for sanctions moves tied to a possible peace deal pathway
If negotiations around Ukraine move toward a framework deal, these licenses can function as pre-positioned “release valves.” Treasury could extend them further or convert them into broader authorizations as part of a stepwise sanctions relief package—sequenced to verified actions. The tell would be coordinated messaging: not just OFAC paperwork, but explicit diplomatic linkage between energy/nuclear permissions and negotiated outcomes.
Historical Context
Reagan’s 1982 Soviet Pipeline Sanctions and Allied Blowback
1982What Happened
The U.S. tried to curb Soviet hard-currency earnings by restricting technology and participation in major gas pipeline projects. European allies pushed back hard, arguing the U.S. was exporting its policy at their expense.
Outcome
Short term: The policy became a transatlantic fight as much as a Kremlin pressure tool.
Long term: It cemented a recurring lesson: energy sanctions work best when allies can absorb the costs.
Why It's Relevant
Today’s Sakhalin-2 carve-out is the modern version of that constraint: allied dependence shapes enforcement.
Nord Stream 2 Sanctions Waiver Politics
2021What Happened
The U.S. used sanctions on a major Russia-to-Europe gas project, then faced pressure to waive or calibrate enforcement to avoid rupturing alliances. The debate wasn’t only about Russia—it was about who pays the price of pressure.
Outcome
Short term: Waiver decisions became signals of alliance management, not just energy policy.
Long term: It reinforced that sanctions often come with built-in escape hatches for partners.
Why It's Relevant
GL 55E and GL 115C are “waivers by another name,” engineered to prevent allied self-harm.
Iran Sanctions and the Rise of Humanitarian ‘Channels’
2010sWhat Happened
As sanctions tightened, governments created narrow channels to permit certain essential trade while keeping the core pressure intact. The channels became politically controversial and operationally complex.
Outcome
Short term: Compliance burdens rose, and disputes shifted to what qualifies for the exceptions.
Long term: Carve-outs became a standard feature of modern sanctions regimes.
Why It's Relevant
The civil nuclear authorization functions like a channel: limited purpose, strict scope, constant scrutiny.