Consolidated Commentary on the 2015 Schlumberger Penalties, the B Whale Corporation Case and the Scope of the Term “U.S. Person” (System Ed. Note)

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (5233 words)

Consolidated Commentary on the 2015 Schlumberger Penalties, the B Whale Corporation Case and the Scope of the Term “U.S. Person” (System Ed. Note)

1) BACKGROUND


The 2015 OFAC and DOJ enforcement actions pertaining to Schlumberger represented the largest fine ever issued in connection with activities that centered almost exclusively around "facilitation." The other relevant documents on the Research System are the following:

*Civil Enforcement Information (FOV) - Schlumberger Oilfield Holdings, Ltd. (SOHL), a subsidiary of Schlumberger Ltd.
*Finding of Violation Notice - Schlumberger Oilfield Holdings, Ltd. (SOHL), a subsidiary of Schlumberger Ltd.
*Statement of Offense (Criminal Case) - Schlumberger Oilfield Holdings, Ltd. (SOHL), a subsidiary of Schlumberger Ltd.
*Plea Agreement - Schlumberger Oilfield Holdings, Ltd. (SOHL), a subsidiary of Schlumberger Ltd.

This commentary also makes use of the information in