The U.S. Department of the Treasury unveiled on Friday the Office of Foreign Assets Control (OFAC) General License 134B, extending the deadline to May 16 for completing transactions involving Russian oil that was already loaded onto ships before the sanctions took effect.
Similar to its predecessors (134 and 134A), this measure doesn't lift sanctions against Moscow but provides a technical window to prevent disruptions in the global energy market.
Treasury Secretary Scott Bessent justified the move by emphasizing that the oil was already en route and its sale wouldn't generate significant financial gains for Russia.
Legally, the mechanism is precise. However, its recent application reveals a deeper truth: U.S. sanctions don't operate as an automatic system but as a flexible tool, influenced by high-level political decisions.
Exclusion of Cuba and Its Immediate Repercussions
The pivotal element appeared in version 134A, issued on March 19, which introduced a specific clause: the exclusion of Cuba. This provision blocks any transactions under U.S. jurisdiction—including banks and insurers—that involve Russian oil destined for the island.
This had an immediate impact. The Sea Horse oil tanker, carrying around 200,000 barrels of Russian diesel, redirected its course towards Trinidad and Tobago shortly after, which analysts interpreted as a direct consequence of the tightened regulations.
The Contradictory Nature of Sanctions
Yet, this pattern was disrupted merely ten days later. On March 30, the Russian tanker Anatoli Kolodkin—owned by the state-run Sovcomflot and sanctioned by the U.S., the EU, and the UK—docked in Matanzas with approximately 730,000 barrels of crude. This was the first significant fuel delivery to Cuba in over three months.
This shipment wasn't covered under the OFAC license. In fact, the license explicitly excluded it. It was made possible by a direct political decision from the Trump administration, which chose not to block the operation.
"If a country wants to send some oil to Cuba, I have no problem with that," President Trump declared. The White House later confirmed that it was a case-by-case assessment, citing humanitarian reasons amid a severe energy crisis on the island.
The Strategic Balance of Pressure
This sequence exposes an apparent contradiction: a legal framework that prohibits and a political decision that permits. But rather than a system failure, the episode illustrates how sanctions truly function.
OFAC defines what is permissible for actors under U.S. jurisdiction but doesn't solely determine what occurs on the ground. Ship interdictions, diplomatic pressure, or the decision to block a specific shipment fall within the political and strategic realm.
In this context, Washington appears to be applying a logic of controlled pressure: restricting the structural supply to the Cuban regime without triggering a sudden collapse that could result in a humanitarian or migration crisis.
The issue is that this strategy has costs.
Russia has seized upon the episode as a political victory, portraying the shipment as a breach of the "energy blockade." This effect could be magnified. The Universal tanker, also from Sovcomflot and sanctioned, is currently heading towards the Caribbean, potentially marking a second shipment in less than a month.
Should this happen, the logic shifts. One shipment may be seen as an exception; two start to resemble a tolerated channel.
At that point, the flexibility that currently manages the crisis might become a crack in the pressure strategy. Because sanctions, by nature, lose their potency when they cease to be predictable.
Ultimately, the case demonstrates that U.S. energy policy towards Cuba isn't governed solely by regulations, but by decisions. The lingering question isn't whether the sanctions can bend, but how far they can do so without losing their effectiveness.
Understanding U.S. Sanctions and Their Impact on Cuba
What is the purpose of OFAC's General License 134B?
OFAC's General License 134B extends the authorization to complete transactions involving Russian oil loaded onto ships before the sanctions took effect, aiming to prevent disruptions in the global energy market.
Why was Cuba excluded from the transactions allowed under General License 134A?
Cuba was excluded to block transactions involving Russian oil destined for the island under U.S. jurisdiction, as part of a strategy to restrict the Cuban regime's access to energy resources.
How did the Trump administration's decision affect the sanctions?
The Trump administration's decision not to block a Russian oil shipment to Cuba highlighted the flexible nature of sanctions, showing that they can be influenced by political decisions.