I. Executive Summary
This companion report provides an overview of U.S. General License 134A and the current state  of U.S., EU, and UK sanctions targeting Gazprom, Rosneft, their subsidiaries, trade unions, and corporate leadership. It is intended to serve as an expert analysis of the current sanctions  landscape against Gazprom and Rosneft, and to outline next steps in sanctions, considering the  alleged war crimes published by the Yale School of Public Health’s Humanitarian Research Lab (HRL) in their report, “Willing Accomplices: Gazprom and Rosneft’s Role in the Transport and  Indoctrination of Ukraine’s Children”, on March 25, 2026. Yale HRL has established with high  confidence that Gazprom and Rosneft, together with their subsidiaries and trade unions,  facilitated the transportation and re-education of at least 2,158 Ukrainian children between  February 2022 and March 2025.

On March 12, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control  (OFAC) issued General License 134. This license allows the sale, delivery, and offloading of  Russian-origin crude oil and petroleum products loaded onto shipping vessels on or before 12  March 2026. This authorization is valid until April 11, 2026. The measure, intended to stabilize  global energy markets in light of disruptions caused by US/Israeli attacks on Iran, applies to  previously sanctioned Russian oil and gas entities such as Rosneft and Gazprom. As a result,  Gazprom and Rosneft will receive revenue from transactions permitted under this temporary 30- day license that would otherwise have been prohibited. This sanctions relief financially benefits  two companies alleged to be implicated in war crimes, based on the open-source investigation by the Yale HRL. This general license should not be extended by OFAC after it expires on April 11, 2026.

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