International Trade > AG Trade Law
12 Jul '17

On January 13, 2017, President Obama issued Executive Order 13761 to be effective on July 12, 2017, which would revoke prior executive orders underlying the Sudanese Sanctions Regulations and effectively terminate the Sudan sanctions program, provided that the incoming Secretary of State (Rex Tillerson) issues a finding regarding Sudan’s cooperation in five key areas of engagement: countering terrorist groups, ending the threat of the Lord’s Resistance Army, ending the government’s offensive internal military operations, ending Sudan’s destabilizing role in South Sudan, and improving humanitarian access. See our prior alert on that executive order for more information.

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17 Jan '17

Introduction

On January 13, 2017, the Obama administration announced that it would lift sanctions imposed on Sudan issued under the Sudanese Sanctions Regulations (SSR), which are administered by the Treasury Department’s Office of Foreign Assets Control (OFAC). The action reverses nearly 20 years of U.S. policy toward Sudan, a country that had been the target of a comprehensive trade embargo due to human rights abuses and support for international terrorism. The United States has stated that its decision comes after months of bilateral engagement with Sudan, which has revealed that country’s support for key U.S. foreign policy goals, such as ceasing hostilities in conflict areas, including Darfur, and enhancing counterterrorism cooperation.

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01 Apr '15

In late March 2015, Schlumberger Oilfield Holdings Ltd. (SOHL), incorporated in the British Virgin Islands, agreed to plead guilty and pay a US$232.7 million penalty to the U.S. government for conspiracy to violate the International Emergency Economic Powers Act (IEEPA) by facilitating transactions in Iran and Sudan and exporting technical services involving these sanctioned countries. The penalty includes a US$155.1 million criminal fine, the largest IEEPA-related fine ever, as well as a US$77.6 million criminal forfeiture. The terms of the plea agreement also impose on SOHL a three-year period of corporate probation.

According to court filings, from 2004 to 2010, SOHL’s Drilling & Measurements (D&M) business segment, a U.S.-based oilfield services provider, facilitated trade with Iran and Sudan from D&M’s Texas office, and D&M employees in the United States made and implemented decisions directly affecting D&M’s Iran and Sudan operations. The court filings also indicate that D&M maintained an illegal process for approving capital expenditure requests for Iran and Sudan. Under this process, D&M personnel operating outside the United States apparently referred to Iran as “Northern Gulf” and Sudan as “Southern Egypt” or “South Egypt” in email communications with D&M personnel in the United States or used incorrect country codes that referred to non-embargoed countries. A U.S. manager then reportedly approved the disguised Iran- and Sudan-related requests.

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