The case involved a $2 million penalty issued in 2017 against ExxonMobil Corp. ("Exxon") for entering into a several contracts with Rosneft, a Russian oil and gas firm. While Rosneft was not blocked under OFAC's regulations, its CEO – who signed contracts with Exxon on behalf of Rosneft – was designated as an SDN. The district court vacated the penalty because it found that OFAC had not provided fair notice of its interpretations of the Ukraine-Related Sanctions Regulations, pointing to conflicting White House press statements and noting that OFAC issued a pertinent FAQ after Exxon's conduct occurred. It remains unclear whether and how OFAC will respond to the decision, so it's worth keeping an eye out for any future developments. Conclusion In light of the spike in OFAC's enforcement actions last year, which have already begun again this year, companies in all industries should take care to ensure that they comply with U.S. sanctions.