On 25 March 2015, it was announced that Schlumberg Oilfield Holdings Ltd, a wholly subisidary of Schlumberg Ltd., has agreed to plead guilty and to pay a total sum of USD 232,708,356 and enter into a three-year deferred prosecution agreement with the Justice Department for, inter alia, violations of the International Emergency Powers Act (“IEEPA”) by willfully facilitating illegal transactions and engaging in trade with Iran and Sudan.
Schlumberg Oilfield Holdings Ltd. is required, according to the plea agreement, to submit to a three-year period of corporate probation and has agreed to continue to full cooperation with the government, to prevent any additional violations of U.S. federal law. In addition to Schlumberg Oilfield Holdings Ltd.’s commitments, under the plea agreement, Schlumberger Ltd., has also agreed that during the three-year term of probation, inter alia, it will (1) cease all operations in Iran and Sudan, (2) report on its compliance with sanctions, (3) respond to any requests for information and materials related to its compliance with U.S. sanctions laws when requested by U.S. authorities, and (4) to hire an independent consultant to review the parent company’s internal sanctions policies and procedures and its internal audits focused on sanctions compliance.
Assistant Attorney General Carlin stated 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 willfully violating the U.S. economic sanctions against those regimes.”
“The International Emergency Economic Powers Act is an essential tool that the United States uses to address foreign threats to national security through the regulation of commerce. Knowingly circumventing sanctions undermines their efficacy and has the potential to harm both U.S. national security and foreign policy objectives. The guilty plea and significant financial penalty in this case underscore that skirting sanctions for financial gain is a risk corporations ought not take”, says Assistant Attorney General Carlin.
The Schlumberg deferred prosecution agreement is at: http://www.justice.gov/opa/pr/schlumberger-oilfield-holdings-ltd-agrees-plead-guilty-and-pay-over-2327-million-violating-us