OFAC Correspondence - Internal OFAC Memorandum in Support of the Penalty Notice issued to ExxonMobil Corporation

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TURBOFAC Commentary (192 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).

2) Many documents serving as notable surrounding context for this memo can be found in the .PDF file associated 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"). To see this document in the context of the complete Administrative Record, see p. 942 of the Exxon Docket File. Note that the Penalty Notice associated with this memorandum was vacated on "fair notice" grounds in Memorandum Opinion and Order in Exxon Mobil Corporation et al v. Mnuchin et al. (N.D. Tex, 2019) (Dkt....

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Internal OFAC Memorandum in Support of the Penalty Notice issued to ExxonMobil Corporation

TURBOFAC Commentary (192 words)