I provided insight for an article published by The New York Times on the $2 million fine that the U.S. Treasury Department charged Exxon Mobil for violating Russian sanctions.  Exxon apparently entered into eight contracts with Rosneft, the Russian state oil company, signed by Rosneft CEO Igor Sechin, who is a prohibited party under U.S. sanctions on Russia.  Exxon was apparently under the impression that the Rosneft CEO could sign the contracts so long as the company was not doing business with him individually. The Treasury Department’s announcement of the penalty refers to the involvement in the matter of Exxon’s “senior-most” executives, which would seem to include Rex Tillerson, who was Exxon’s CEO at the time and is now the U.S. Secretary of State. Exxon has subsequently sued the Treasury Department related to this matter.

The full article, “Stakes for Exxon in Sanctions Case Go Far Beyond a $2 Million Fine,” was published by The New York Times on July 21, 2017, and is available online.