The $36 Billion Question: The Economic and Humanitarian Consequences of Extending Russia’s Oil Waivers
The $36 Billion Question: The Economic and Humanitarian Consequences of Extending Russia’s Oil Waivers
The Impact of Extending the U.S. Office of Foreign Asset Control General License 134 Series on Russian Oil Revenues, War Financing, and Humanitarian Implications for Ukraine.
Executive Summary
This independent assessment concludes that extension of the United States Office of Foreign Assets Control General License 134 series for Russian-origin crude oil and petroleum products from May to December 2026 would generate an additional $36.1 billion in Russian export revenues—equivalent to 2.1 percent of Russia’s GDP and 13.3 percent of its total exports—thereby materially sustaining Russia’s war economy in Ukraine. Drawing on high-frequency Brent-Urals spread data, production series, and counterfactual modeling across pre-sanctions, post-Crimea, and war-era periods, the analysis projects that continued licensing would maintain a compressed price discount and elevated output volumes, whereas expiry would restore wider discounts and constrain production. These financial gains would directly benefit Rosneft and Gazprom—entities implicated by the Yale Humanitarian Research Lab in the forcible transfer and deportation of Ukrainian children, a policy qualified by the March 2026 United Nations Independent International Commission of Inquiry as crimes against humanity. The limited use of strategic petroleum reserve releases and expanded use of bypass pipelines could offer alternatives to stabilize global markets without providing budgetary relief to actors complicit in systematic violations of international humanitarian law; allowing the license to expire on schedule while implementing such measures could better align energy security with the imperative to curtail funding for aggression and alleviate humanitarian suffering in Ukraine.
Key Findings
1. This report estimates that if the United States allows General License 134B to expire, the loss in oil export value for Russia between May and December 2026 would amount to $36.1 billion USD.
2. Our findings suggest that if OFAC issues additional Russia-related general licenses for the remainder of 2026, Russia would gain the equivalent of 2.1% of GDP and 13.3% of exports.
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