Compliance with U.S. Sanctions Policy

U.S. economic sanctions policy presents an ever-evolving challenge to companies, particularly energy-related companies, that do business internationally. When the U.S. government abruptly reinstated economic sanctions against Libya in early 2011, one of the country’s largest independent petroleum refiners turned to the PRG team for assistance in understanding the policy to ensure compliance.  The PRG team brought both its legal and government relations expertise to bear for the company.  As U.S. policy changed over subsequent months, the PRG team worked closely with the company’s in-house counsel to evaluate an opportunity for the company to be one of the first purchasers of crude oil from rebel forces in Libya.  The PRG team helped coordinate communications with the U.S. Treasury Department, and drafted and submitted the formal legal notices required in connection with the transaction.  In the end, the company complied with U.S. law and the transaction was lauded as a significant achievement for U.S. policy towards Libya by demonstrating that the Libyan rebels could successfully negotiate significant transactions.