Schlumberger Oilfield Holdings Ltd. or SOHL, a wholly-owned subsidiary of Schlumberger Ltd. (SLB), has agreed to enter a guilty plea and to pay a $232.71 million penalty to the United States for conspiring to violate the International Emergency Economic Powers Act or IEEPA by willfully facilitating illegal transactions and engaging in trade with Iran and Sudan.
SOHL's monetary penalty includes a $77.57 million criminal forfeiture and an additional $155.14 million criminal fine. The criminal fine represents the largest criminal fine in connection with an IEEPA prosecution.
The plea agreement, which is contingent upon the court's approval, also requires SOHL to submit to a three-year period of corporate probation and agree to continue to cooperate with the government and not commit any additional felony violations of U.S. federal law.
In addition to SOHL's commitments, under the plea agreement, SOHL's parent company, Schlumberger Ltd., has also agreed to additional terms during the three-year term of probation, inter alia: maintaining its cessation of all operations in Iran and Sudan; reporting on the parent company's compliance with sanctions; responding to requests to disclose information and materials related to the parent company's compliance with U.S. sanctions laws when requested by U.S. authorities; and hiring an independent consultant to review the parent company's internal sanctions policies and procedures and the parent company's internal audits focused on sanctions compliance.
The guilty plea concludes a joint investigation commenced in 2009 and led by the Justice Department's National Security Division, the U.S. Attorney's Office for the District of Columbia and the U.S. Department of Commerce's Bureau of Industry and Security (BIS) Dallas Field Office.
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