Mistaken Sanctions Relief: How U.S. General License 134A Benefits Russian Energy Companies Implicated in War Crimes Against Ukrainian Children

This companion report to the Yale Humanitarian Research Lab 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. 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. The temporary 30-day sanctions relief provided by General License 134A will financially benefit these two companies alleged to be implicated in war crimes. This general license should not be extended by OFAC after it expires on April 11, 2026.