Schlumberger Oilfield Holdings, Ltd


Industry: Oil & Gas
Underlying Misconduct: Sherman Act
Matter Type: DOJ Criminal
Relevant Jurisdiction(s): United States Attorney District of Columbia
Penalties: Fine
Fine Amount: $500,000 or a fine of twice the gross gain or gross loss, whichever is greater
Reporting Agencies:
Resolution Form: Plea Agreement
Agreement Date: March 24, 2015
Monitor Reference Term: Compliance Consultant
Monitor Identity:
Monitorship Term: 3 Years
Monitor Selection Process:

Prior to retaining the Consultant, Schlumberger Ltd. shall give notice to the Government of the Consultant it has selected and provide the Government with an opportunity to object. Schlumberger Ltd. shall provide the Government a copy of its agreement with the Consultant.

Time to Propose Monitors:
Time to Engage Monitor:
Time to First Report: within 6 months
Reporting Frequency:
Monitor Required Qualifications:

{l) demonstrated expertise with respect to compliance with sanctions pursuant to IEEPA, (2) experience designing and/or reviewing corporate compliance policies, procedures and internal controls concerning compliance with IEEPA sanctions, and (3) sufficient independence from Schlumberger Ltd. to ensure effective and impartial perfonnance of the Consultant' s duties as described

Summary of Monitor's Scope:

The Consultant's objective is to conduct a twoMpart review and issue subsequent written reports that are disclosed to Schlumberger Ltd. and the Government.
When reviewing Schlumberger Ltd.'s Sanctions Policies and Procedures, the scope of the Consultant's Reviews shall be to assess whether, during the probation period, appropriate policies and procedures are in place, whether those policies and procedures identify responsible parties1 and whether there exist any material gaps In those policies and procedures specifically with respect to Sanctions Policies and Procedures regarding training, subject matter, personnel, and operations covered.

Summary of Monitor's Activities:

To review and assess in a professionally independent and objective fashion Schlumberger Ltd.'s processes, policies, and procedures related to compliance with sanctions pursuant to IEEPA ("Sanctions Policies and Procedures") and the non­ privileged sanctions trade compliance audits conducted by Schlumberger Ltd.'s internal audit function (''Sanctions Audit Reports").
Upon completion of each of the Consultant's Reviews, the Consultant shall issue a written report (the "Consultant's Reports") within sixty (60) days following the conclusion of the respective Consultant Review .

Monitor's Restrictions:

Schlumberger Ltd. agrees that no attomey-dient relationship shall be formed between it and the Consultant. In addition, Schlumberger Ltd. shall require that the Consultant enter into an agreement with Schlumberger Ltd. that provides that for the period of engagement and for a period of two years from completion of the engagement that the Consultant shall not enter Into any employment, consultant, attorney­ client, auditing, or other professional relationship with Schlumberger Ltd., or any of its present or former affiliates, subsidiaries, directors, officers, employees or agents acting in their capacity as such.

Documents Uploaded: Schlumberger-Plea-Agreement-DOJ-24Mar2015.pdf