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ExxonMobil Sanctions Penalty: Lessons for Companies and Practitioners

, New York Law Journal

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Daniel Pilarski sees two important lessons from the Treasury Department's $2 million penalty against ExxonMobil for its dealings with a sanctioned officer of a Russian company, even though the company itself was not subject to these sanctions: Conduct diligence and get representations and covenants not only from counterparty companies, but also the company's officers and directors. And exercise caution in relying on informal guidance in dealing with sanctions.

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