Settlement Agreements between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Cameron International Corporation and Schlumberger Rod Lift, Inc.

Release date
09/27/2021
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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $1,423,766 settlement with Cameron International Corporation (“Cameron”), a Houston, Texas-based supplier of goods and services for the oil and gas industries and a subsidiary of Schlumberger Limited (“Schlumberger”).  Cameron has agreed to settle its potential civil liability for apparent violations of Directive 4 issued pursuant to Executive Order 13662 of March 24, 2014, “Blocking Property of Additional Persons Contributing to the Situation in Ukraine,” (“E.O. 13662”), as implemented by the Ukraine-Related Sanctions Regulations, 31 C.F.R. part 589.  Specifically, between July 2015 and November 2016, U.S.-person senior managers at Cameron approved contracts for its subsidiary, Cameron Romania S.R.L. (“Cameron Romania”), to supply goods to Gazprom-Neft Shelf, a Russian energy firm subject to the restrictions of Directive 4 of E.O. 13662.   Cameron Romania’s requests to Cameron for approval of the contracts variously referenced the provision of oil production or exploration goods to Gazprom-Neft Shelf’s Arctic offshore project and that the Russian Arctic was the destination of the oil-related goods.  OFAC determined that Cameron did not voluntarily self-disclose the apparent violations and that the apparent violations constitute a non-egregious case.

Separately, OFAC today announced a settlement with Schlumberger Rod Lift, Inc (now d/b/a Lufkin Rod Lift.).  Schlumberger Rod Lift, Inc (“SRL”), a subsidiary of Schlumberger Lift Solutions LLC (“SLS”), which itself was a U.S. subsidiary of Schlumberger Limited (“Schlumberger”) based in Frisco, Texas, has agreed to settle its potential civil liability for an apparent violation of OFAC’s now-repealed Sudanese Sanctions Regulations, 31 C.F.R. part 538.  Specifically, between December 2015 to April 2016, three U.S. person employees of SRL facilitated the sale and shipment of oilfield equipment from a Canadian subsidiary of Schlumberger to a Chinese joint venture of Schlumberger for onward delivery to Sudan.  The facilitation by SRL’s employees of a transaction to deliver oilfield equipment to Sudan was, at the time of the transaction, an apparent violation.  OFAC determined that SRL’s conduct was non-egregious and was not voluntarily self-disclosed.

For more information, please visit the following web notice for the Cameron matter and the following web notice for the SRL matter.