Exxon Mobil wins motion against OFAC

On 31st December 2019, the U.S. District Court for the Northern District of Texas vacated the Office of Foreign Assets Control’s (OFAC’s) Penalty Notice of 2017 against Exxon Mobil Corporation, ExxonMobil Development Company and ExxonMobil Oil Corporation (collectively ‘Exxon Mobil’). The Court concluded that Exxon Mobil lacked fair notice (in accordance with the Due Process Clause of the Fifth Amendment) that their conduct violated the Ukraine-Related Sanctions Regulations.