On 7 August, the US Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it issued a Finding of Violation to Schlumberger Oilfield Holdings, Ltd., a wholly owned subsidiary of Schlumberger Ltd. OFAC found that the Schlumberger unit knowingly and wilfully violated the sanctions laws between February 2004 and June 2010, by allowing U.S.-based personnel to approve capital expenditure requests from Iran and Sudan for new tools and other purchases, arrange for drilling equipment transfers from non-embargoed oilfield locations to Iran and Sudan, provide technical services to maintain drilling equipment in Iran and Sudan, and make business planning decisions concerning Iran and Sudan.

This involved the same violations for which Schlumberger Oilfield Holdings had pleaded guilty and agreed to pay a criminal fine of $155,138,904 and a forfeiture of $77,569,452 in March of this year. Because those penalties had already been imposed, OFAC closed its investigation with a finding of violation rather than an additional civil monetary penalty. The Justice Department described the $155 million fine as the largest criminal fine ever imposed under the International Emergency Economic Powers Act (IEEPA), although several banks have paid substantially larger total amounts for IEEPA violations after forfeitures are included.