By Michael Casey, Brendan Hanifin and Emerson Siegle (July 21, 2017, 5:06 PM EDT) -- On July 20, 2017, the U.S. Treasury Department's Office of Foreign Assets Control penalized ExxonMobil Corp. and two of its U.S. subsidiaries (collectively, "ExxonMobil") $2 million for violations of the Ukraine-related sanctions regulations. The penalty stems from legal documents that ExxonMobil entered into with Rosneft OAO in May 2014, less than two months after OFAC introduced sanctions in response to Russia's invasion of Ukraine. OFAC found ExxonMobil's conduct to violate the sanctions because the documents at issue were countersigned by Rosneft's CEO, Igor Sechin, who was personally targeted by U.S. sanctions when he executed them. Within hours of the penalty announcement, ExxonMobil filed a lawsuit in the Northern District of Texas, challenging OFAC's action and requesting that the court hold unlawful and set aside the imposed penalty....
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