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It may seem like a Herculean task -- but it can be done. I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks. One big reason -- geography is an important limiter on sanctions risks. The ability to
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OFAC’s guidance is intended to ease the burden on an otherwise difficult compliance problem. Companies have to act in good faith to avoid transacting business involving Russian crude oil that has been sold above the $60 per barrel price cap. For some industry players, compliance is straightforward. However, for
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The Biden Administration recognizes that the Russian Price-Cap Policy imposes serious burdens on U.S. energy companies and industries that provide ancillary services to the energy sector. It is even more complicated given the EU framework and another set of guidance related to the oil price cap. To ameliorate