Internal OFAC Memorandum in Support of the Pre-penalty Notice issued to ExxonMobil Corporation

Date issued: May. 29 2015

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TURBOFAC Commentary (334 words)

Notes:

1) For substantive comment on this document and the Exxon case as a whole, see Consolidated Comment on the Civil Penalty Issued in ExxonMobil Corporation (2017), the Administrative Record Underlying the Penalty, and the Ensuing Litigation (System Ed. Note). To see this document in the context of the complete Administrative Record, see p. 981 of the Exxon Docket File.

2) Many documents serving as notable surrounding context for this memo can be found in the .PDF file associated with the Research System entry titled All Notable Documents Filed in Connection with Exxon Mobil Corporation v. Mnuchin et al., (N.D. Tex. 2017) (the "Exxon Docket File").

3) Except with respect to the following point, to the degree that aspects of this memorandum are discussed outside of the context of Consolidated Comment on the Civil Penalty Issued in ExxonMobil Corporation (2017), the Administrative Record Underlying...