Tagged: OFAC sanctions

The Strange Case of OFAC Against Exxon for Sanctions Violations

In a bizarre enforcement action, The Treasury Department’s Office of Foreign Asset Control (“OFAC”) assessed a $2 million civil monetary penalty against ExxonMobil (“Exxon”) for violations of the Ukraine sanctions. (Copy Here). OFAC’s enforcement action boiled down to Exxon’s execution of eight legal documents with Igor Sechin, the CEO of Rosneft OAO (“Rosneft”), who is a Specially Designated Nation and Blocked Person on what is...

TD Bank and Sanctions Violations

Sanctions enforcement continues to be a significant risk. With the focus on unraveling elaborate corporate ownership schemes, the risk of conducting business with sanctioned individuals or entities is increasing. The Treasury Department’s Office of Foreign Asset Control has increased expectations regarding corporate compliance programs. In addition, OFAC encourages voluntary disclosures when violations occur, and has set out an elaborate scheme regarding transparency. On the criminal...