The DOJ and Commerce Department said Wednesday a unit of Paris-based Schlumberger Ltd. has agreed to plead guilty and pay a $232.7 million penalty for conspiracy to violate trade sanctions with Iran and Sudan.
Schlumberger Oilfield Holdings will plead guilty to conspiring to violate the International Emergency Economic Powers Act. Executive orders under the law ban most trade with Iran and Sudan.
A Sugar Land, Texas-based subsidiary of Schlumberger Ltd. called Drilling and Measurements provided oilfield services for 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.
The plea agreement (pdf) still needs federal court approval.
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 BVI-incorporated company has offices in Paris, Houston, and the Hague.
The penalty includes a $77.5 million criminal forfeiture and a $155 million criminal fine. It’s the biggest criminal fine in connection with a prosecution under the International Emergency Economic Powers Act.
Parent company Schlumberger Ltd. agreed to continue cooperating with the Justice Department and other agencies during the three-year probation. It also agreed to hire an independent consultant to review company-wide internal sanctions policies and compliance audits.
In 2009, Schlumberger agreed to stop taking new oilfield service contracts in Iran. Two years later, the company voluntarily stopped providing any oilfield services in Iran and the Republic of the Sudan (North Sudan).
Schlumberger Limited trades on the NYSE under the symbol SLB. It has about 120,000 employees worldwide.
Richard L. Cassin is the publisher and editor of the FCPA Blog. He can be contacted here.