The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $78,750 settlement with S&P Global, Inc. (“S&P Global”) a New York-based company that provides business information and financial analytics. S&P Global has agreed to settle its potential civil liability for apparent violations of the Ukraine-Related Sanctions Regulations, 31 C.F.R. part 589, specifically Directive 2 issued pursuant to Executive Order 13662 of March 24, 2014, “Blocking Property of Additional Persons Contributing to the Situation in Ukraine,” (“E.O. 13662”). The apparent violations occurred between August 2016 and October 2017, when S&P Global and a company it acquired reissued and re-dated multiple invoices to continue to extend credit to JSC Rosneft (“Rosneft”), a state-owned Russian oil company, in violation of the debt and equity restrictions set forth under E.O. 13662. After reissuing and re-dating four invoices to extend the original payment dates, S&P Global ultimately accepted past-due payments totaling $82,500 from Rosneft. OFAC determined that S&P Global did not voluntarily self-disclose the apparent violations and that the apparent violations constitute a non-egregious case.
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