In March 2015, we resolved the investigation by the U.S. Department of Justice (the “DOJ”) into past violations of U.S. sanctions regarding our non-U.S. subsidiaries’ historical operations in Iran and Sudan that occurred between 2004 and 2010.
As a result, Schlumberger Oilfield Holdings Ltd. (“SOHL”), a non-US subsidiary of Schlumberger Limited, entered into a plea agreement with the DOJ whereby SOHL pleaded guilty to one criminal count of conspiracy to violate the International Emergency Economic Powers Act and paid approximately $233 million in fines and penalties. The plea agreement also required SOHL to submit to a corporate probation.
Prior to entering into the plea agreement, we ceased oilfield service operations in Iran and Sudan.
The plea agreement expired on April 30, 2019. As a result, the corporate probation also expired, and the matter with the DOJ is closed. Schlumberger Limited and its subsidiaries operations remain committed to complying with all applicable laws. In connection with the plea agreement, we took numerous remedial actions, including:
- we hired an independent consultant to review our internal sanctions policies and procedures and our internal audits focused on sanctions compliance;
- we briefed the Nominating and Governance Committee of our Board of Directors, as well as our full Board, numerous times over the course of the corporate probation;
- our compliance systems and processes were audited twice over the past four years by our independent consultant; and
- as a result of these audits, we further embedded our mature trade compliance program within our global businesses, thus enhancing our effective compliance program.