To avoid the impression that it was extending credit to Rosneft, S&P reissued its original $82,500 invoice with a new date of August 26, 2016, more than one year after first preparing it. In October, Rosneft made a $55,000 partial payment for the invoice, which led S&P to issue two new $13,750 invoices for the remaining amount in late November 2016. Rosneft paid one of those invoices just before the end of the year but did not pay the second, which led S&P to reissue the final $13,750 invoice with yet another new date of September 5, 2017. Rosneft paid this invoice in early October 2017. In the end, S&P was paid the total amount of its original invoice to Rosneft. But to get there, it issued four new invoices in the process, each time violating the debt and equity restrictions set forth under E.O. 13662. Three takeaways for companies doing business with entities on OFAC's Sectoral Sanctions Identification ("SSI") List: