On April 30, Schlumberger Oilfield Holdings Ltd. (“SOHL”)—a wholly owned subsidiary of Schlumberger Ltd.—pled guilty to facilitating illegal transactions with Iran and Sudan.  As part of the plea agreement, SOHL agreed to forfeit more than $77 million and pay a $155.1 million fine—the largest criminal fine in connection with an International Emergency Economic Powers Act prosecution to date.  In the agreed-upon statement of facts, the company acknowledged that its U.S. employees (1) approved capital expenditure requests for oilfields in Iran and Sudan; (2) provided technical assistance to personnel located in Iran and Sudan; and (3) made day-to-day business decisions on behalf of personnel involved in Iran and Sudan.  SOHL also acknowledged that in email communications its employees referred to Iran as “northern Gulf” and Sudan as “South Egypt.”  In addition to the monetary penalties, SOHL agreed to a three-year probation term.  SOHL’s parent company also agreed, during this probation term, that it would cease all operations in Sudan and Iran, report its compliance with sanctions, and hire an independent consultant to review its internal sanctions policies and procedures.  United States v. Schlumberger Oilfield Holdings, Ltd., 15-cr-41 (D.D.C).  DOJ Press Release