EXXON MOBIL CORP · FY 2018 

Legal Proceedings

XOM
  EXXON MOBIL CORP · FY 2018 

Legal Proceedings

Item 3. Legal
Proceedings

In
a matter reported in the Corporation's Form 10-Q for the second quarter of
2018, the State of Ohio Department of Natural Resources, Division of Oil &
Gas Resources Management (ODNR) and XTO Energy Inc. (XTO) signed a Compliance
Agreement on December 21, 2018, regarding alleged violations by XTO of the Ohio
Revised Code, Ohio Administrative Code, and implementing regulations arising
out of the Schnegg well incident in Belmont County, Ohio, in early 2018. The
Compliance Agreement settles the following alleged actions of XTO: (1) causing
brine to be discharged and contact the ground and/or surface water; (2) failure
to place cement in the casing string per Ohio codes; (3) allowing a well to
flow gas uncontrolled; (4) failure to construct, drill and operate a well in
the manner as permitted and planned; and (5) failure to notify the ODNR upon
discovery a well had sustained annular pressure above the prescribed pressure.
The penalty assessment was $850,000, half paid to the ODNR on January 15, 2019,
and half to be paid to 29 agencies located in Belmont County as designated by
the ODNR.

In
another matter relating to the Schnegg well incident, reported in the
Corporation's Form 10-Q for the second quarter of 2018, the State of Ohio
Environmental Protection Agency (OEPA) and XTO signed Final Findings and Orders
on December 28, 2018, regarding OEPA allegations that XTO violated the Ohio
Revised Code and implementing regulations, including but not limited to: (1)
failure to maintain and operate its facility in a manner using good pollution
control practices; (2) failure to provide a malfunction report; (3) failure to
complete and properly report quarterly inspections; and (4) failure to submit
site-specific work practice plans within applicable time limits. The penalty
assessment of $150,000 was paid on January 21, 2019, half to the OEPA and half
to a Supplemental Environmental Project.

As
reported in the Corporation's Form 10-Q for the first quarter of 2018, the
Corporation received a proposed agreed order from the Texas Commission on
Environmental Quality (TCEQ), dated March 15, 2018, related to routine Title V
air operating permit investigations conducted by the TCEQ in 2017 of the
Baytown Refinery in Texas. The proposed agreed order alleged that the refinery
failed to authorize, monitor, or keep records on certain equipment and to
comply with certain flare or fuel gas monitoring system availability requirements
or concentration limits. After receipt of additional information from
ExxonMobil and further evaluation of the alleged violations, the TCEQ has
issued a revised proposed agreed order, reducing the number of alleged
violations and agreeing to an administrative penalty of $56,596 in settlement
of these matters. The Agreed Order was signed by ExxonMobil on December 18,
2018, and ExxonMobil paid $28,298 on January 10, 2019. The balance will be paid
to a Supplemental Environmental Project upon endorsement by the TCEQ.

As
last reported in the Corporation's Form 10-Q for the third quarter of 2018, on
July 20, 2017, the United States Department of Treasury, Office of Foreign
Assets Control (OFAC) assessed a civil penalty against Exxon Mobil Corporation,
ExxonMobil Development Company and ExxonMobil Oil Corporation for violating the
Ukraine-Related Sanctions Regulations, 31 C.F.R. part 589. The assessed civil
penalty is in the amount of $2,000,000. ExxonMobil and its affiliates have been
and continue to be in compliance with all sanctions and disagree that any
violation has occurred. ExxonMobil and its affiliates filed a complaint on July 20,
2017, in the United States Federal District Court, Northern District of Texas
seeking judicial review of, and to enjoin, the civil penalty under the
Administrative Procedures Act and the United States Constitution, including on
the basis that it represents an arbitrary and capricious action by OFAC and a
violation of the Company's due process rights.

Refer
to the relevant portions of "Note 16: Litigation and Other Contingencies"
of the Financial Section of this report for additional information on legal
proceedings.

Item 4. MINE SAFETY DISCLOSURES