17
Also, on September 27, OFAC announced a settlement with Schlumberger Rod Lift, Inc., a former subsidiary of
Schlumberger Lift Solutions LLC (SLS), which itself was a U.S. subsidiary of Schlumberger Limited. SRL agreed
to pay $160,000 to settle its potential civil liability for one apparent violation of OFAC's Sudanese sanctions
program. Specifically, between December 2015 to April 2016, three U.S. employees of SRL facilitated the sale
and shipment of oilfield equipment from a Canadian subsidiary of Schlumberger to a Chinese joint venture of
Schlumberger. The equipment was then delivered to Sudan. According to OFAC, each of the employees
involved was aware that the goods were destined for Sudan prior to arranging the shipment of the goods and
that the sale was prohibited by U.S. sanctions. OFAC determined that SRL's conduct was non-egregious and
was not voluntarily self-disclosed.
ABU DHABI
AUSTIN
BEIJING
BRUSSELS
DALLAS
DUBAI
FRANKFURT
HONG KONG
HOUSTON
LONDON
MENLO PARK
MILAN
MUNICH
NEW YORK
PARIS
RIYADH*
ROME
SAN FRANCISCO
SÃO PAULO
SHANGHAI
SINGAPORE
TOKYO
TORONTO
WASHINGTON, DC
Shearman & Sterling has long advised financial institutions and commercial
businesses on the most complex sanctions issues. If you have any
questions, please feel free to contact one of our partners or counsel.
Authors
& Contributors
Philip Urofsky
Danforth Newcomb
Stephen Fishbein
Brian G. Burke
Christopher L. LaVigne
Barnabas Reynolds
Mark D. Lanpher
Paula Howell Anderson
Adam B. Schwartz
Katherine J. Stoller
Associate Contributors
Jacob Fields
Cole Pritchett
Blair Campion
Related Services
Sanctions, Litigation, Anti-Corruption & Foreign Corrupt Practices Act (FCPA)
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