Schlumberger, the world’s largest oil-field services company, has agreed to plead guilty and pay a penalty of $232,708,356 for violating US sanctions by facilitating trade with Iran and Sudan. Under the plea agreement, Schlumberger Oil Holdings Ltd (SOHL), the subsidiary responsible for the violations, will also be subject to a 3-year period of corporate probation during which time it will have to maintain its cessation of operations in Iran and Sudan. In addition, its parent company will be required to hire an independent consultant to review its sanctions policies and compliance procedures.
The US Department of Justice stated that from around early 2004 until June 2010, Schlumberger provided oilfield services to customers in Iran and Sudan through non-US subsidiaries. Further, Schlumberger employees approved and disguised requests from Iran and Sudan for the manufacture of new oilfield drilling tools and the spending of money for certain company purchases. It facilitated trade with Iran and Sudan from offices in Sugar Land, Texas.
Speaking on 25 March 2015, US Assistant Attorney General Carlin said that “Over a period of years, Schlumberger Oilfield Holdings Ltd conducted business with Iran and Sudan from the United States and took steps to disguise those business dealings, thereby wilfully violating the US economic sanctions against those regimes”. US Attorney Machen added that “Even if you don’t directly ship goods from the United States to sanctioned countries, you violate our laws when you facilitate trade with those countries from a US-based office building”
The penalty against SOHL comprises $77,569,452 criminal forfeiture, and a criminal fine of $155,138,904, the largest ever levied in connection with an IEEPA prosecution.