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.

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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.

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based in Frisco, Texas, has agreed to settle its potential civil liability for an apparent violation of OFAC’s now-repealed Sudanese Sanctions Regulations, 31 C.F.R. part 538.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

For more information on this specific action, please visit this page.