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.

This entry was posted in Iran, USA by Maya Lester QC. Bookmark the permalink.

About Maya Lester QC

Maya Lester QC has a wide ranging practice in public law, European law, competition law, international law, human rights & civil liberties. She has a particular expertise in sanctions. As the most recent (2016) Chambers & Partners directory put it, she "owns the world of sanctions". She spent 2011-12 in New York at Columbia Law School lecturing and writing on sanctions. She represents and advises hundreds of companies and individuals before the European and English courts and has acted in most of the leading cases, including Kadi, Tay Za, Central Bank of Iran, NITC and IRISL.

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