"With Exxon's Russia Sanctions Penalty, OFAC Issues Stern Reminder: Sanctions Risks are Not Limited to Counterparties"

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August 15, 2017

On July 20, 2017, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued a penalty notice to ExxonMobil for violation of Ukraine/Russia-related sanctions targeting Russian government officials and their associates. The enforcement action has garnered significant attention for its political implications, but the political intrigue may obscure a crucial reminder for international investors and global companies: thorough and verified knowledge of your counterparty and associated persons and entities is necessary because any involvement with sanctioned individuals and entities raises sanctions compliance risks.

In this client alert, RK&O attorneys Audrey Laning Ingram, Michael D. Mann and Jamie A. Schafer break down OFAC's reminder and the importance of thoroughly vetting counterparties, including associated individuals and entities.

Click here to read the full client alert.