• Recent Developments in Sanctions Enforcement: Schlumberger Oilfield Holdings Pleads Guilty to Criminal Sanctions Charges Related to Conduct that “Facilitated” Business from the United States; PayPal Resolves Apparent Sanctions Violations with OFAC Caused in Part by the Failure to Employ Adequate Screening Technology and Procedures
  • May 8, 2015 | Authors: Nicolas Bourtin; H. Rodgin Cohen; Elizabeth T. Davy; Mitchell S. Eitel; Jared M. Fishman
  • Law Firm: Sullivan & Cromwell LLP - New York Office
  • On March 25, 2015, Schlumberger Oilfield Holdings, Ltd. (“SOHL”), a non-U.S. wholly-owned subsidiary of Schlumberger Ltd. (“Schlumberger”), also a non-U.S. corporation and one of the largest oilfield services organizations in the world, entered into an agreement with the U.S. Department of Justice (“DOJ”) to plead guilty to conspiring to violate the International Emergency Economic Powers Act (“IEEPA”) by facilitating the provision of oilfield services to customers in Iran and Sudan through Schlumberger’s U.S.-based business segment.