Tagged: Ukraine Russia Sanctions

Webinar: How to Implement An Effective Sanctions Compliance Program

How to Implement an Effective Sanctions Compliance Program Tuesday, December 19, 2017 Sign Up Here The Department of Justice and the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) have aggressively enforced comprehensive and complex sanctions statutes and regulations. Global companies have to design and implement an effective sanctions compliance program in order to avoid sanctions enforcement risks. Join Michael Volkov, CEO of The...

Episode 7 — The Perils of Compliance with the Russia Sanctions Program

The Ukraine-Russia Sanctions program is a complex set of executives orders, statutes and regulations defining prohibited business transactions with Russian entities and individuals.  The sanctions program was instituted in 2014 in response to Russia’s invasion of the Ukraine and annexation of Crimea.  In August 2017, Congress enacted statues and directed OFAC to implement additional regulations.  Congress acted in response to fears that the Trump Administration...

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...