Those included "reckless disregard for US sanctions requirements when it failed to consider warning signs associated with dealing in the blocked services of (a sanctioned person), that "Exxon Mobil's senior-most executives knew of Sechin' s status. when they dealt in the blocked services of Sechin", that the deals "caused significant harm to the Ukraine-related sanctions program objectives" and that the company "is a sophisticated and experienced oil and gas company that has global operations and routinely deals in goods, services and technology subject to U.S economic sanctions and USA export controls".
Yet the Treasury Department said that Exxon's "senior-most executives" knew Sechin was blacklisted when two of its subsidiaries signed deals with him. Igor Sechin, president of Rosneft, had been on the department's List of Specially Designated Nationals and Blocked Persons list (SDN), establishing a clear violation of the sanctions by ExxonMobil.
The sanctions prohibit USA citizens or those located in the United States from dealing with those on the blacklist, such as Sechin. Rosneft itself was not subject to sanctions at the time.
Concerns about Tillerson's potential conflict of interest dominated his confirmation hearings in January, and the secretary has recused himself from matters dealing with his former company. He is now responsible for US foreign policy, which includes helping to make sanctions decisions.
The State Department declined to comment, referring questions to Exxon.
"The secretary continues to abide by his ethical commitments, including that recusal from Exxon-related commitments", said State Department spokeswoman Heather Nauert.
Though the State Department plays a part in formulating broad sanctions policy, former USA officials and sanctions experts said it was unlikely the agency had a role in deciding the fine announced on Thursday.
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The Treasury Department "is trying to retroactively enforce a new interpretation of an executive order" inconsistent with its prior guidance, Jeffers said.
"Ofac's action is fundamentally unfair". The company said the eight legal documents it signed were related to ventures with Rosneft, not Sechin personally.
"ExxonMobil followed the clear guidance from the White House and Treasury Department when its representatives signed documents involving ongoing oil and gas activities in Russian Federation with Rosneft - a non-blocked entity - that were countersigned on behalf of Rosneft by CEO Igor Sechin in his official representative capacity". The executive order sought to block any American property holdings by any Russian official or person acting on behalf of the Russian government.
In April of that year at a Treasury briefing, it was explicitly stated that sanctions were applicable to Igor Sechin "individually", not in his capacity as the head of a Russian government-owned corporation.
"ExxonMobil demonstrated reckless disregard for USA sanctions requirements", the filing says, calling this "an egregious case" and adding, "ExxonMobil caused significant harm to the Ukraine-related sanctions program objectives".
After the Ukraine-related sanctions put in place under President Barack Obama, Tillerson saw Exxon's stake in a lucrative offshore drilling project with Rosneft come under threat.
Russian President Vladimir Putin and Rex Tillerson, then Exxon Mobil's CEO, at a ceremony in 2012.
Nevertheless, in May 2014 Tillerson chose not to attend an oil industry forum in Moscow, instead sending top lieutenant Neil Duffin, who signed an agreement with Sechin to explore for oil in the Arctic Ocean.
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