Treasury Focusing Russia Sanctions Enforcement on 'Willful' Violators, Official Says
The Treasury Department will prioritize most enforcement of its price cap on Russian oil against “willful violators,” a senior agency official stressed this week, reminding industry that due diligence and recordkeeping could significantly mitigate any potential penalties. Elizabeth Rosenberg, Treasury’s assistant secretary for terrorist financing and financial crimes, said the agency established its safe harbor protocol (see 2211230047) so it can target service providers intentionally looking to support Russia’s oil industry and protect those conducting good-faith sanctions compliance.
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Rosenberg, speaking at an economic sanctions conference, said Treasury is “focusing enforcement” to penalize “those who attempt to defraud or mislead coalition businesses into unwittingly providing services for oil purchased above the cap.” Speaking more broadly, she also said “dirty Russian money” can only enter the U.S. if banks, investment advisers, brokers, capital venture firms and others help facilitate those transactions.
“We expect financial institutions and all covered institutions to proactively investigate and screen for these types of risks and report any suspicious activity to Treasury,” Rosenberg said. But she also stressed that OFAC may impose penalties “based on strict liability -- knowledge of prohibited dealings is not required. And while OFAC of course takes into account whether a subject was witting, Treasury will not hesitate to act where we see control failures or lapses in vigilance that enable evasion to occur.”