Russian diesel bill would revoke GL 135 and bar replacement licenses
U.S. diesel importers should review suspension and termination rights for a loss of GL 135 authorization. If enacted as drafted, the bill would nullify the license immediately and bar covered replacement authorizations for three years after enactment.
The House proposal would restrict the licensing flexibility preserved in the Graham sanctions law. For U.S. diesel buyers, the contract question is how to handle a loss of permission that Treasury could not remedy with a replacement license.
The committee-posted bill would nullify GL 135 at enactment, even before its scheduled April 7, 2027 expiry, and bar Treasury from authorizing covered, otherwise-prohibited Russian energy transactions for three years. The proposal creates no new restriction today. GL 135 also does not resolve the separate statutory restriction on U.S. imports of Russian energy. Buyers should review cargo, payment and termination terms for obligations that could outlast the authorization.
Read the full analysis: Russian Diesel Bill Would Bar New Energy Licenses for Three Years.