Pre-penalty Notice (details relayed in other writing) - ConocoPhillips

Date issued: Apr. 08 2004

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TURBOFAC Commentary (580 words)

Notes:

1) Document contains an excerpt of the CEO of ConocoPhillips' answers to questions asked in connection with his testimony before Congress.

Mulva recounts the details concerning two settlement agreement entered into with OFAC prior to 2006, when OFAC began disclosing the details of its enforcement actions (but OFAC did disclose that the penalty amounts were $16,500.00, paid by ConocoPhillips on behalf of Conoco, Inc. and Conoco Middle East Ltd.).[1]

The was penalty issued on the basis of the ITR (now the ITSR) as it existed from 1999-2000, prior to the blocking of all GOI property (EO 13599 and 560.211) and prior to all U.S.-owned or -controlled entities being subject to the general...