OFAC Loses Exxon Sanctions Enforcement Case
In an interesting end of year decision, issued on December 31, 2019, a District Court in Dallas issued a rejected OFAC’s enforcement action against Exxon Corporation imposing a $2 million penalty for violation of the Russia Sanctions Program. (Copy of decision is here). OFAC suffered a rare rebuke after extensive litigation and it will be interesting to see if OFAC appeals the District Court’s decision....