Short answer
EU law bans Russian diesel imports, but EU-flagged ships may carry it between non-EU countries if it was bought at or below the $100-a-barrel price cap. The Malta-flagged Agioi Fanendes loaded about 40,000 metric tons at Primorsk on Oct. 22. Malta is seeking price-cap attestations.
- What happened The Agioi Fanendes loaded about 40,000 metric tons at Primorsk on Oct. 22.
- Why it is allowed EU ships may carry Russian diesel to third countries under the price cap.
- What the US changed GL 135 allows US imports through April 7, 2027.
- What to watch An attestation, and whether the ship reaches New York.
Last checked
Key facts
| OFAC General License 135 | Issued Oct. 9, 2026; valid through April 7, 2027 |
| G7/EU price cap on diesel | $100 per barrel since Feb. 5, 2023 |
| Agioi Fanendes cargo | About 40,000 metric tons, loaded at Primorsk on Oct. 22 |
| Reported New York arrival | Nov. 7 (destination changed to 'for orders' on Oct. 23) |
| EU-listed shadow-fleet vessels | 673 after the 21st package (July 23, 2026) |
| Volume Trump announced | More than 300,000 tons of diesel |
What happened with the Agioi Fanendes?
On Oct. 9, 2026, President Donald Trump said after a call with Vladimir Putin that Russia would "immediately supply over 300,000 Tons of Diesel Fuel to the American and Global Marketplace," according to the Kyiv Independent. The same day, the US Treasury said OFAC was issuing a temporary general license for Russian diesel.
Russia partially lifted its diesel export ban from Oct. 10 and resumed loadings at the Baltic port of Primorsk, Reuters reported via Baird Maritime. The first post-deal cargo, about 40,000 tonnes of ultra-low sulphur diesel loaded on Oct. 13, went to Morocco, not the US.
The Malta-flagged Agioi Fanendes then loaded about 40,000 metric tons at Primorsk on Oct. 22. Reuters, cited by the Kyiv Independent, reported it was bound for New York and due on Nov. 7. The Kyiv Independent said the ship is owned by the Greek company Eastern Mediterranean Maritime. On Oct. 23, its MarineTraffic destination changed to "for orders," so its final port is not confirmed.
- Oct. 9: Trump announces the diesel supply; OFAC issues General License 135
- Oct. 10: Russia partially lifts its diesel export ban
- Oct. 13: First post-deal cargo loads, headed to Morocco
- Oct. 22: Agioi Fanendes loads at Primorsk
- Oct. 23: Ship's listed destination changes to 'for orders'
How can an EU ship carry Russian diesel if the EU bans it?
Two separate EU rules apply. The first is an import ban: since Feb. 5, 2023, the EU has barred seaborne imports of Russian refined products, following its crude ban of Dec. 5, 2022. From Jan. 21, 2026, it also banned refined products made in third countries from Russian crude, with exemptions for listed partner countries, according to Baker McKenzie. These rules govern what enters the EU.
The second is the G7/EU price cap. It governs EU ships and services that move Russian oil between non-EU countries. EU operators may carry such cargoes if they were bought at or below the cap and the operator holds an attestation. The European Commission told the Kyiv Independent that EU operators may only provide maritime transport for Russian oil products sold at or below the relevant caps.
A shipment from Russia to the US never enters the EU, so the import ban does not apply. The price cap does. Ukraine's sanctions envoy Vladyslav Vlasiuk put it this way: "An EU-flagged, EU-managed ship may carry Russian diesel only if it was bought at or below the $100 a barrel price cap."
Enforcement at sea has limits. Per the Kyiv Independent, a ship can be stopped inside an EU state's 12-mile territorial waters, but in international waters flag-state law applies. Finland's Border Guard said no intercept was planned. That puts the compliance check on Malta as the flag state. Malta's sanctions unit said it is seeking price-cap attestations from the vessel's owners and operators.
| Product type | Current cap | Notes |
|---|---|---|
| Premium-to-crude products (diesel, gasoline) | $100 per barrel | In place since Feb. 5, 2023 |
| Discount-to-crude products (fuel oil, naphtha) | $45 per barrel | In place since Feb. 5, 2023 |
| Crude oil (EU and UK) | $44.10 per barrel | From Feb. 1, 2026; down from $47.60; automatic adjustment suspended until July 14, 2027 |
What did the US license change, and what did it leave open?
OFAC General License 135 temporarily authorizes certain transactions involving Russian-origin diesel, including importation into the US, through April 7, 2027, according to Clyde & Co. It covers US sanctions only.
The license does not affect sanctions imposed by other Price Cap Coalition members. EU and UK persons remain restricted unless the supply is price-cap compliant. A US license therefore does not clear a Maltese-flagged ship with Greek ownership. EU law still decides whether that ship may carry the cargo.
Lawyers at Clyde & Co also note a domestic gap. The 2022 Ending Importation of Russian Oil Act banned US imports of Russian oil products, including diesel, unless the President certifies certain conditions to Congress. GL 135 does not resolve that statute.
Who is affected, and why does it matter?
For Russia, the deal reopens an export channel. Deputy Prime Minister Alexander Novak said diesel exports could rise to between three million and 3.5 million tonnes per month by year-end, according to Reuters.
For the US market, volumes are small relative to demand. Vlasiuk called the deal "economically pointless," noting the US consumes about 3.5 million tons of diesel weekly. On that figure, Trump's 300,000 tons is a small share of one week's use, and the Agioi Fanendes cargo is about 40,000 metric tons.
The deal is politically contested. Senators Jeanne Shaheen, Chuck Schumer and Elizabeth Warren called it "a total betrayal of Ukraine," according to the Kyiv Independent.
For shipowners and flag states in the EU, the case tests how the price cap works when the US loosens its own rules. The EU has listed hundreds of shadow-fleet tankers, but those listings target specific vessels. A mainstream EU-flagged ship falls under the price-cap rules instead.
| EU package | Date | Vessels added | Total listed |
|---|---|---|---|
| 18th | July 18, 2025 | 105 | Not stated |
| 19th | Oct. 23, 2025 | 117 | 557 |
| 20th | April 23, 2026 | 46 | 632 |
| 21st | July 23, 2026 | 41 | 673 |
What to watch next
The dates below come from official texts and reporting. None of them settles whether this cargo complies with EU rules.
- Nov. 7: Reported arrival date of the Agioi Fanendes in New York, now listed as 'for orders'
- Malta's request for price-cap attestations from the ship's owners and operators
- April 7, 2027: OFAC General License 135 expires
- July 14, 2027: End of the EU suspension of automatic crude cap adjustment
- A possible full EU ban on maritime transport of Russian oil: the 20th package created the legal basis, with timing to be set by the Council
What is not confirmed?
Several points remain open as of Oct. 24, 2026. Treat them as unknown until officials or the companies involved confirm them.
Disclaimer: This explainer is for general information only. It is not financial, investment, legal or trading advice, and it does not recommend buying or selling any asset.
Availability: Sanctions rules differ by country. The licenses, products and services described here may not apply or be available in your country or region.
- The buyer, seller and purchase price of the Agioi Fanendes cargo are not public. No attestation had been confirmed as of Oct. 23.
- Whether the ship will discharge in New York, since its destination changed to 'for orders'.
- Whether the EU's $100 product cap has been revised since February 2023. No source in our review shows a change.
- Details of GL 135 come from Clyde & Co and press summaries, not the OFAC text itself.
- Trump has since claimed larger future volumes. Those are his statements and do not appear in Treasury text.
- Nothing reported indicates that Eastern Mediterranean Maritime broke any law. Compliance depends on an attestation that has not been made public.
FAQ
Does the EU allow Russian diesel imports?
No. The EU has banned seaborne imports of Russian refined products since Feb. 5, 2023, and from Jan. 21, 2026 also banned products refined in third countries from Russian crude, with some partner-country exemptions.
Can an EU-flagged ship carry Russian diesel to the US?
Only if the diesel was bought at or below the $100-a-barrel price cap and the operator holds an attestation, according to the European Commission and Ukraine's sanctions envoy. The US license does not change EU rules.
What is OFAC General License 135?
It is a US Treasury license issued Oct. 9, 2026 that temporarily authorizes certain transactions involving Russian-origin diesel, including US imports, through April 7, 2027. Lawyers note it does not resolve the 2022 US law banning Russian oil product imports.
Why can't the EU stop the tanker at sea?
Per the Kyiv Independent, a ship can be stopped within an EU state's 12-mile territorial waters, but flag-state law applies in international waters. Finland's Border Guard said no intercept was planned.
How much Russian diesel is heading to the US?
Trump said Russia would supply more than 300,000 tons to the American and global market. The Agioi Fanendes carries about 40,000 metric tons, and its final destination is unconfirmed.
Sources
- European Commission – EU adopts 20th package
- US Treasury OFAC – Feb 2023 price cap determination (scanned PDF)
- Kyiv Independent – How EU ships are still able to carry Trump's Russian diesel
- Kyiv Independent – First tanker with Russian diesel heads to US
- Clyde & Co – OFAC GL 135
- Reuters via Baird Maritime – diesel loadings resume at Primorsk
- WilmerHale – product price caps
- Skadden – 21st package
Figures change. Check the primary sources below.