Securities and Exchange Commission filings show ExxonMobil conducted business with three state sponsors of terrorism — Iran, Syria, and Sudan — while president-elect Donald Trump's secretary of state pick, Rex Tillerson, was the corporation's CEO.
"The filings, from 2006, show that the company had $53.2 million in sales to Iran, $600,000 in sales to Sudan and $1.1 million in sales to Syria" between 2003 and 2005, according to USA Today, which first reported on Democratic super PAC American Bridge's findings.
In a 2006 response letter, Richard E. Gutman, then ExxonMobil’s assistant general counsel, downplayed the SEC's concern that the corporation hadn't disclosed to shareholders its dealings with the three countries:
[We] have had very limited interaction with Syria, Sudan, and Iran. When viewed in terms of the scale of our business (revenues of $371,000,000,000; petroleum product sales of 3,000,000,000 barrels), we are confident that these interactions are not material by any reasonable measure, that they certainly do not rise to the level where separate disclosure would be either legally necessary or appropriate, and that they do not pose a material risk for our security holders. Furthermore, we do not believe these de minimis activities would be qualitatively important to a reasonable investor.
ExxonMobil told USA Today, "the transactions were legal because [the offending subsidiary,] Infineum, a joint venture with Shell Corporation, was based in Europe and the transactions did not involve any U.S. employees."