On July 20, 2017, the U.S. Department of Treasury’s Office of Foreign Assets Controls (OFAC) assessed a $2 million penalty against U.S. oil conglomerate ExxonMobil for its violation of U.S. trade sanctions on Russia enacted in response to Russia’s 2014 intervention in Ukraine (the Russia-Ukraine sanctions). The penalty was assessed because of ExxonMobil’s dealings with a sanctioned officer of a Russian company, even though the company itself was not subject to these sanctions. ExxonMobil is challenging the assessment, and has filed suit to have the penalty set aside.
The assessment illustrates two important lessons for companies and practitioners:
