A Houston-based subsidiary of oilfield services company Schlumberger has been fined approximately $1.4 million by the U.S. Treasury’s Office of Foreign Assets Control (OFAC) for selling goods to a Russian-based energy firm that was under U.S. sanctions.
OFAC said in a press release Monday that Cameron International Corp. sold goods in 2015 and 2016 to Gazprom-Neft Shelf, a wholly owned subsidiary of sanctioned Russian energy company OJSC Gazprom Neft.
The sanctions were imposed “to impede Russia’s ability to develop so-called frontier or unconventional oil resources,” OFAC said.
According to the settlement order, Cameron Romania signed five contracts with Gazprom-Neft Shelf and completed 111 shipments of oil production and exploration goods to an offshore oil platform located in the Russian Arctic and operated by the sanctioned entity.
OFAC indicated the violation was non-egregious but was not voluntarily self-disclosed. Schlumberger did not respond to a request for comment.
Compliance takeaways: Schlumberger acquired Cameron in April 2016, after two of the contracts with Gazprom-Neft Shelf had already been signed. Three more contracts would be signed between Cameron and Gazprom-Neft Shelf while Schlumberger was the owner. The sanctions violations were discovered by Schlumberger in “post-acquisition compliance review and integration efforts,” OFAC said.
Cameron had twice reported potential sanctions violations to OFAC, in June 2017 and again in December 2017, but OFAC determined the reporting was insufficient to constitute voluntary self-disclosure.
Four U.S.-based senior managers at Cameron signed the contracts with Gazprom-Neft Shelf, despite knowing the deals were sending goods to a sanctioned entity.
“Even large, sophisticated companies with OFAC compliance programs face sanctions risks if they do not develop internal controls that account for their day-to-day operations and procedures and consider how a variety of different types of conduct can implicate applicable prohibitions,” OFAC wrote in its settlement order.
A former Schlumberger subsidiary, Schlumberger Rod Lift of Frisco, Texas, also agreed to a settlement order Monday with OFAC regarding sanctions violations in Sudan. The company, now Lufkin Rod Lift, will pay $160,000 to settle allegations it facilitated the 2015-16 sale of oilfield equipment from a Canadian subsidiary of Schlumberger to a Chinese company for ultimate delivery to a customer in Sudan. Sanctions against Sudan have since been lifted.
OFAC considered the conduct non-egregious but noted the violations were not voluntarily self-disclosed.