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based in Frisco, Texas, has agreed to settle its potential civil liability for an apparent violation of OFAC’s now-repealed Sudanese Sanctions Regulations, 31 C.F.R. part 538.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.