Written by Jonathan Ledwidge, who delivers Redcliffe Training’s Advanced Sanctions: Securities & Investments course.
So, how do the recent Russian sanctions relief and the Iranian situation stack up in 2026? And how does this relate to the US domestic agenda?
The Domestic Politics Driving US Sanctions Policy
As the price of Brent crude and WTI soared above US$100, President Donald Trump, already worried about Republican Party prospects in the November midterms, is trying to soften the impact of oil prices on already disgruntled US consumers. Should his opponents in the Democratic Party gain control of the House, and possibly even the Senate in November, his Administration would come under greater Congressional oversight.
Which, to say the least, would be unwelcome.
Yet, the fact that President Trump is offering these concessions to Russia at a time when that country is offering satellite imagery and drone technology to assist Iran in targeting US soldiers and assets is a truly startling development.
We have a US President who fears for his domestic agenda, almost as much as he fears his country’s active adversaries, and that is now driving US Sanctions policies and regulations.
Breaking Down General Licence 133
This is the context within which we now examine the scale of the Sanctions relief. Offered by
General Licence 133 issued on March 5, 2026, for any crude of Russian origin on any vessel loaded as at that date. General Licence 133 allows all transactions incident to the sale, transport, delivery or offloading of Russian crude to an Indian port, and to a purchaser that is an entity organised under the laws of India.
To achieve this, General License 133 suspends the relevant provisions of the following Sanctions authorities until April 4, 2026:
- Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587
- Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589
- Iranian Transactions and Sanctions Regulations, 31 CFR part 560
- Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 CFR part 544
- Iranian Financial Sanctions Regulations, 31 CFR part 561
- Iranian Sector and Human Rights Abuses Sanctions Regulations, 31 CFR part 562
- Global Terrorism Sanctions Regulations, 31 CFR part 594
- Executive Order 13876 of June 24, 2019 (“Imposing Sanctions With Respect to Iran”)
- Executive Order 13902 of January 10, 2020 (“Imposing Sanctions With Respect to Additional Sectors of Iran”)
- Executive Order 13949 of September 21, 2020 (“Blocking Property of Certain Persons with Respect to the Conventional Arms Activities of Iran”)
Let us first state the obvious:
An entity organised under the laws of India could still be owned by Russian persons or any other nationality, for that matter.
As such, General License 133 either advertently or inadvertently directly facilitates the sale of Russian crude beyond Indian markets.
Now we must examine the list of suspended Sanctions regulations as they constitute an intriguing cocktail of foreign and domestic policy.
Russian Sanctions Provisions Suspended
The first, Russian Harmful Foreign Activities Sanctions, was introduced under multiple Executive Orders 14024, 14066, 14068, 14071 and 14114. These effectively blocked major Russian financial, marine shipping, and industrial enterprises, as well as Russian participation in US financial markets, with special anti-facilitation measures for foreign financial institutions.
The Regulations further prohibited the delivery of a whole range of services to Russian persons.
Given the stated objectives of General License 133 and President Trump’s specific agenda, the suspension of these is entirely rational.
The second, Ukraine-/Russia-Related Sanctions Regulations are merely the codification of the original CAATSA (Countering American Adversaries Through Sanctions Act) Sectoral Sanctions. CAATSA Directives 1-4 severely restrict financing to the financial, energy, defence and intelligence, and the shale exploration sectors of the Russian economy.
Therefore, the suspension of these Sanctions is again consistent with the stated objectives of General License 133, given President Trump’s specific agenda.
Why Are Iran Sanctions in Here Too?
The other 8 Sanctions regulations all relate to Iran, and thus, we must examine and understand their relevance.
Both Iran and Russia are effectively outcasts from the Western financial and commercial system.
As Russia became more isolated post its invasion of Ukraine, it developed extensive links with Iran. As well as other US-Sanctioned countries such as
Venezuela and North Korea. Naturally, this cooperation has included a range of joint Sanctions-evasion strategies and schemes covering logistics, shadow fleets, oil, weapons, and payment systems.
For example, Iran supplied Russia with Shahed drones. These have been used in the war against Ukraine, and their payment systems, Russia’s SPFS and Iran’s SEPAM, have been linked. As a consequence, there are a significant number of Russian persons under both US / Russia Sanctions and US / Iran Sanctions.
It is entirely logical that for President Trump’s sanctions relief to work as envisaged, the impacted Russian persons would need relief from both sets of regulations.
Yet this does not entirely explain all the sanctions authorities suspended.
For example, why would anyone sanctioned under Global Terrorism Sanctions Regulations, 31 CFR part 594, be given relief? Perhaps this is merely a sign of the level of urgency with which a potentially nervous White House believes it has to act.
General Licence 134: Even Broader Relief, One Week Later
This assertion has now effectively been confirmed by the release of yet another General License, No. 134.
General Licence 134 is effective from March 12, 2026, until April 11, 2026. It was issued just one week after General Licence 133.
It removes the requirements for offloading at Indian ports and purchase by an entity constituted under Indian laws. As such, Russia now has even greater latitude to sell its products in any market until the expiration of the License.
What This Means for Compliance Teams
The war shows no sign of stopping in the immediate future.
Consequently, there are increasing risks of further damage to Gulf oil facilities, further surges in the price of oil, and attendant market uncertainty. It is quite likely that, as President Trump assesses the risks to his domestic agenda, we will see more General Licenses, more lifting of Sanctions, and more fevered attempts to subdue troubled oil markets.
For persons subject only to US Sanctions, it is very important to ensure that any financing or transactions executed under these Licences must be wholly completed before the expiration date of the relevant license.
As at this time, however, UK and EU Sanctions on Russia remain unchanged.
The sanctions landscape is shifting faster than ever, with General Licences being issued, amended, and expanded within the space of a week.
For compliance professionals working in securities and investments, keeping pace is a regulatory necessity. Redcliffe Training's
Advanced Sanctions: Securities & Investments course gives you the practical, in-depth knowledge of sanctions frameworks, the interplay between US, UK, and EU regimes, and managing the compliance risks that come with an increasingly volatile geopolitical environment.
FAQ
What specific legal issues arise from the use of a General License issued by the Treasury?
CAATSA began life as Executive Orders 13660, 13661, and 13662. These were later strengthened and codified into law, CAATSA, by Congress during the first Trump Administration when the President appeared reluctant to impose Sanctions on Russia. This is in contrast to “Russian Harmful Foreign Activities Sanctions”, which have been imposed primarily by Executive Orders, including 14024, 14066, 14068, 14071 and 14114.
The suspension of CAATSA is, in effect, a Presidential rule overriding a Congressional Act, which is illegal under the law. However, the Republican controlled Congress has said nothing; they have been subservient to the Executive. This is just one of the many reasons why President Trump is eager not to lose control of Congress to his Democratic opponents in the November mid-term elections. That said, so far, we have not heard any major pushback from Democrats on this either.
This is not the first time Presidential power has been used to illegally override laws passed by Congress. The Foreign Corrupt Practices Act (FCPA) has been at the centre of US attempts to fight bribery and corruption since its passage in 1977. It focuses primarily on US firms, but like US Sanctions, if a foreign entity has a US nexus, e.g., business operations in the US or executing transactions in US dollars. At the very beginning of his Presidency, Trump stated that his Administration would not enforce the FCPA. A feckless Congress said nothing.
It would be interesting if state prosecutors in, for example, New York or California, decided to prosecute these laws under dual sovereignty if the offending entity violated both the state and federal law. Interesting.
Do the General Licenses provide relief for Iran?
The Note to paragraph (b) of General Licence 133 specifically states:
(b) This general license does not authorize any other transactions or activities prohibited by any other Executive order or by any part of 31 CFR chapter V not referenced in this general license, including any transaction or activity involving Iran, the Government of Iran, or Iranian origin goods or services that is prohibited by the Iranian Transactions and Sanctions Regulations (31 CFR part 560), except as authorized by paragraph (a)This asserts that in this specific context, only such Sanctions relief directly facilitates the intent of the General License.
However, the amended General Licence 134A, issued on March 19, 2026, states:
(b) This general license does not authorize: (1) Any transaction involving a person located in or organized under the laws of the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, the Covered Regions of Ukraine, as defined by E.O. 14065, the Crimea Region of Ukraine, as defined by E.O. 13685, or any entity that is owned or controlled by or in a joint venture with such persons;This amended General Licence effectively clears up any doubt that there might have been some intention to provide Iran and other comprehensively Sanctioned countries and regions with Sanctions relief, either directly or indirectly.
Venezuela is the notable omission here.
Do these General Licences impose any reporting requirements?
These General Licenses do not impose any reporting requirements on entities relying on them to execute transactions with Russian entities and/or in respect of facilitating business with sanctioned vessels.
Jonathan Ledwide is a Chartered Certified Accountant and MBA graduate (Bayes Business School) with a distinguished career spanning Price Waterhouse, Manufacturers Hanover Trust, CIBC, and ABN AMRO, bringing deep expertise in investment banking governance, audit, risk, and compliance across major global financial centres. He has delivered financial crime compliance training — covering AML, sanctions, tax evasion, and terrorist financing — to frontline staff and senior managers at institutions including HSBC, Société Générale, and Lloyds across 50+ countries, and served as Master Trainer on HSBC's global financial crime programme.