Sanctions-related Judicial Opinion - Exxon Mobil Corporation et al v. Mnuchin et al. (N.D. Tex, 2019) (Dkt. 110)

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TURBOFAC Commentary (622 words)

Notes:

1) This Memorandum Opinion and Order vacates Penalty Notice - ExxonMobil Corporation (2017) on "fair notice" grounds. For further discussion of the contents of the opinion, see Consolidated Comment on the Civil Penalty Issued in ExxonMobil Corporation (2017), the Administrative Record Underlying the Penalty, and the Ensuing Litigation and Notes Common to "5XX.101" Provisions (Titled "Relation of this part to other laws and regulations") (System Ed. Note). See also General Note on "Fair Notice".

The opinion generally avoided the merits of the substantive arguments underlying the penalty notice, e.g. whether the execution of a contract could be considered a "receipt of a service" within the meaning of the basic blocking prohibition. The opinion did, however, conclude that the text of the basic blocking regulation at issue and other boilerplate definitional provisions in the

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Exxon Mobil Corporation et al v. Mnuchin et al. (N.D. Tex, 2019) (Dkt. 110)

TURBOFAC Commentary (622 words)