Exxon Mobil Corp. v. Corporación Cimex, S. A. (Cuba) · ¶32

In 1952, the State Department adopted what is known as the “restrictive” theory of foreign sovereign immunity. See Turkiye Halk Bankasi A.S. v. United States, 598 U. S. 264, 271 (2023). Courts continued to defer to the State Department, but the State Department would support immunity only for a foreign sovereign’s public acts and not for its strictly commercial acts.

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