Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.
Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).
Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category).
Please contact [email protected] or [email protected] with any questions on search results and efficiency.
Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.
Consolidated Comment on the Civil Penalty Issued in ExxonMobil Corporation (2017), the Administrative Record Underlying the Penalty, and the Ensuing Litigation (System Ed. Note)
1) BACKGROUND
This consolidated comment addresses certain aspects of the 2017 penalty assessed against ExxonMobil (Civil Enforcement Information - ExxonMobil Corporation (2017)), and the various documents contained in the Administrative Record underlying the penalty.
At the time the litigation challenging the penalty was initiated, it was of only two OFAC penalty assessments from 2006 through late-2019 to be challenged in an Article III, U.S. Federal Court. The other was Epsilon Electronics Inc. (1 of 2 - 2014) On Jan. 21, 2019, the trial court hearing the Exxon case issued Memorandum Opinion and Order in Exxon Mobil Corporation et al v. Mnuchin et al. (N.D. Tex, 2019) (Dkt. 110). The Northern District of Texas vacated the Penalty Notice issued to Exxon on "fair notice"...