US Ends Permit for Russian Energy Transactions – Trump’s Sanctions Trump Card?

The US Treasury, under the Trump administration, allowed an exception for energy transactions with Russian financial institutions to expire as planned on March 12, 2025.

Reuters received confirmation from the US Treasury that General License 8L, which Atlantic Council Fellow Eddie Fishman described as an “energy loophole” in Russian sanctions in an X update, has expired. 

“At long last, banks will not be able to pay Russia in hard currency for its oil and gas exports,” Fishman said. 

What is General License 8 and what does its expiry mean? 

General License 8, introduced via the US Office of Foreign Assets Control, was an exception that allowed entities to conduct limited businesses with sanctioned Russian banks, particularly on energy-related transactions. 

General License 8L – introduced by former US President Joe Biden on Jan. 10, shortly before he left office – was meant to wind down all those transactions and was scheduled to expire on Thursday – a last call to clear the cheques, in simple terms. 

The US Treasury, under US President Donald Trump, confirmed to Reuters that it did not extend the license.

A Treasury spokesperson told Reuters that the administration “remains focused on ending the fighting and fostering negotiations to end the war [in Ukraine]” and “[would] continue to implement our sanctions, which remain one of the levers to facilitate these goals.” 

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Reuters also noted that US Treasury Secretary Scott Bessent previously criticized Biden’s Russian sanctions for being too soft. 

No more Russian energy?

Not fully – Fishman noted that transactions can technically be carried out via non-sanctioned Russian banks.

“It’s still not airtight, as Russia is not under a full financial embargo. A non-sanctioned Russian bank could emerge to collect energy payments, putting the ball back in Trump’s court. This will take time, however, as we saw when Gazprombank was sanctioned last fall,” Fishman said in a comment under his X update. 

In another comment, he said it would require a full embargo like those imposed on Iran “for this to really bite (and stick).”

How this would play out remains to be seen. While the list of sanctioned institutions listed under the license was limited, with the inclusion of 10 institutions such as Russia’s Alfa-Bank and VTB Bank, it also applied to Russia’s Central Bank and “any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest” – meaning it might also include institutions related to those listed. 

It might also be possible for foreign banks to directly engage with Russia for the transactions, bypassing US institutions altogether – however, how and whether they might be targeted by US sanctions as a result would be a different question altogether.