Schlumberger Subsidiary Pleads Guilty and Agrees to a $232.7M Penalty for Sanctions Program Violations

Drilling and Measurements (D&M), a Texas-based subsidiary of Schlumberger Ltd. was charged with providing oil field services to Iran and Sudan through overseas subsidiaries of Schlumberger Oilfield Holdings from early 2004 through June 2010.  D&M personnel outside the United States often sent emails to a U.S.-based D&M manager justifying requests for services in Iran and Sudan, the DOJ said.  The emails used code names, referring to Iran as “Northern Gulf” and Sudan as “Southern Egypt” or “South Egypt.” When work orders for Iran and Sudan were entered into the D&M computer system, numerical codes for non-embargoed countries were used to disguise the true locations.  “These efforts were deliberately taken and demonstrate the company’s involvement in contriving ways intended to evade restrictions imposed by U.S. sanctions,” the DOJ said.

Schlumberger Oilfield Holdings will plead guilty to conspiring to violate the International Emergency Economic Powers Act, under which Executive Orders ban most trade with Iran and Sudan. Schlumberger Oilfield Holdings, a wholly-owned subsidiary of parent Schlumberger Ltd., will pay the full $232.7 million penalty and have a three-year period of corporate probation.  The penalty includes a $77.5 million criminal forfeiture and a $155 million criminal fine. It’s the largest criminal fine to-date for a violation of the International Emergency Economic Powers Act.

The parent company Schlumberger Ltd. agreed to continue cooperating with the DoJ and other Government agencies during the three-year probation. It also agreed to hire an independent consultant to review company-wide internal sanctions policies and conduct compliance audits.

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