OFAC's Russia-related General License 134B expires at 12:01 a.m. EDT on May 16 — ten days from now. The license, issued April 17, authorizes transactions ordinarily incident to the sale, delivery, and offloading of Russian-origin crude oil and petroleum products loaded on vessels as of that date. It replaced GL 134A, which had expired April 11. [1] The paper's May 5 read framed the license as still operative inside the Hormuz risk envelope. Ten days later the envelope itself has shifted — Brent crashed below $100 on the project pause day, and the MOU window has opened.

The decision points on the cliff are three. Treasury extends 134B to 134C, narrowing or widening the vessel-loading cutoff date. Treasury lets it cliff, leaving cargoes mid-voyage stranded — a market dislocation Bessent has signaled he wants to avoid. Or Treasury pairs the license with a Russia-track sanctions move that Moscow has not signaled willingness to negotiate against. The third option requires diplomatic ground that is not visible in current readouts.

The license excludes any transaction involving Iran, North Korea, Cuba, or the occupied Ukrainian regions, and any cargo from entities owned or controlled by Iranian sanctioned parties. [2] The narrow vessel-loading-date carve-out means only cargoes underway at the April 17 cutoff fall within authorization. Energy compliance teams across the maritime sector have been documenting reliance on the license since March 12, when GL 134 was first issued amid the Hormuz crisis.

Treasury Secretary Bessent's office has been silent on the renewal question this week. The market has priced an extension. If 134B cliffs cleanly, the disruption to Russian oil flows currently underway and the secondary Iran sanctions overlap would be the first real-time stress test of the post-Hormuz sanctions architecture.

-- SAMUEL CRANE, Washington