Russia-related General License 134B expires at 12:01 a.m. EDT Friday, May 16 — nine days from Thursday, eight days after Iran's response window opens. [1] The Office of Foreign Assets Control issued the license on April 17, authorizing transactions necessary for "the delivery and sale of crude oil and petroleum products of Russian Federation origin loaded on vessels as of April 17, 2026." [2] No GL 134C has been pre-announced.

The May 6 paper's account of the cliff approaching May 16 opened the count at T-10. Today's standard advances to T-9 and frames the credibility test the next license decision implies. Treasury Secretary Scott Bessent said publicly on April 15 that the administration would not renew the Russian-oil waiver. [3] OFAC issued the renewal — GL 134B — on April 17. Two days, full reversal, on the record.

The architecture is precise. GL 134B authorizes shipping, insurance, bunkering, pilotage, registration, classification, salvage, and emergency-repair services for Russian crude already loaded as of the April 17 cutoff. It explicitly excludes "any transaction involving a person, entity or joint venture located in Iran, North Korea, Cuba, or parts of Ukraine." [4] Russian-presidential-envoy Kirill Dmitriev has placed the affected volume at roughly 100 million barrels of crude on tankers worldwide — a figure that survived the original GL 134 of March 12, the GL 134A amendment of March 19, and the GL 134B rollover of April 17. [5]

The carve-out language matters because it puts Iran outside the envelope on Treasury's own face. The same week the United States is asking Tehran to accept a memorandum of understanding mediated through Pakistan, OFAC's documentary architecture authorizes Russian crude to clear the global market and prohibits any of that flow from touching Iranian counterparties. The asymmetry is a feature, not a bug, of an enforcement architecture the administration has chosen.

The Bessent reversal is the credibility line. Paul Weiss's client memo on the energy-sector general licenses lays the timeline cleanly: Bessent's "We will not be renewing" public statement, followed two days later by OFAC's renewal. [4] No public administration explanation has been offered for the reversal. The Russian crude affected is largely already in transit; letting the waiver lapse without alternative arrangements would have stranded vessels mid-voyage and produced a market shock the administration was not willing to take in the same week it was trying to lower oil prices toward the Iran deal.

The choice on May 16 is therefore a known set. OFAC can issue GL 134C, extending the wind-down again. It can let GL 134B lapse, accepting the disruption to Russian crude clearance. Or it can issue an amended license that narrows or broadens the coverage. The first option preserves the architecture and absorbs another credibility hit. The second produces a shipping crisis on top of the Hormuz crisis. The third allows the administration to claim adjustment without surrender.

What the date does not allow is silence. Whatever OFAC does on May 16 will be a documented act of policy. The Russian oil tape — Brent reaction on the day, vessel-tracking patterns the week after, China's import behavior over June — will read the act for what it is. The Iran deal week sets the political optics: a Russian-oil renewal next to an Iran MOU produces an asymmetry the discourse will name immediately. A non-renewal removes the asymmetry but creates the disruption.

The FOMC meeting under Warsh runs T-10 to GL 134B. The Pakistan IMF tranche prints T-1. Aramco prelim arrives Sunday. The OPEC+ June add takes effect June 1. The next nine days carry one Treasury decision that defines the sanctions architecture the rest of the calendar runs through.

OFAC has issued three Russia oil general licenses in nine weeks. The fourth is the one on a clock the Iran deal calendar is now reading.

-- SAMUEL CRANE, Washington