In addition, D&M’s Texas office also apparently illegally exported services to Iran and Sudan, according to the court filings. This reportedly occurred when D&M oilfield technicians located in Iran and Sudan experienced technical problems; the technicians queried a computer system that automatically routed questions to a local technical expert. Sometimes, however, the queries were automatically routed to D&M personnel located in the United States, resulting in prohibited technical services being provided to Iran or Sudan.
Though SOHL had a U.S. sanctions compliance program, it reportedly failed to adequately train D&M personnel to comply with the program.
As part of the plea agreement, Schlumberger Ltd., SOHL’s parent company, with principal offices in Paris, Houston and The Hague, has agreed to cooperate with U.S. authorities during SOHL’s three-year probation. It has also agreed to hire a consultant who will review the parent company’s internal sanctions policies, procedures and company-generated sanctions audit reports. In addition, the parent company guaranteed and secured payment of the US$232.7 million penalty by its subsidiaries.
Press reports regarding this plea agreement include a statement from Schlumberger that “[t]his plea fully resolves the investigation of the Company, and we understand there is no ongoing investigation of Company personnel. The Company cooperated with the investigation, and we are satisfied that this matter is finally resolved.”
The plea agreement is contingent on court approval in the U.S. District Court for the District of Columbia.
To learn more, see the DOJ’s press release and coverage in Fortune and Reuters.