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

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TURBOFAC Commentary (5043 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