OFAC Due Diligence and Attestation Requirements (Part IV of IV)
OFAC’s guidance is intended to ease the burden on an otherwise difficult compliance problem. Companies have to act in good faith to avoid transacting business involving Russian crude oil that has been sold above the $60 per barrel price cap. For some industry players, compliance is straightforward. However, for a number of players who do not normally have access to specific pricing information, due diligence...
