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Enforcement Release: September 27, 2021
OFAC Settles with Cameron International Corporation for Its Potential Civil Liability for Apparent Violations of Ukraine-Related Sanctions Regulations
Cameron International Corporation (“Cameron”), a Houston, Texas-based supplier of goods and services for the oil and gas industries, and a subsidiary of Schlumberger Limited (“Schlumberger”) of Curaçao, Netherlands, has agreed to pay $1,423,766 to settle its potential civil liability for apparent violations arising from its provision of services to the Russian energy firm Gazprom-Neft Shelf for an Arctic offshore oil project. Cameron provided these services when U.S.-person senior managers at Cameron approved five contracts for its foreign subsidiary, Cameron Romania S.R.L. (“Cameron Romania”), to supply goods to Gazprom-Neft Shelf’s Prirazlomnaya offshore oil production and exploration platform, located in the Russian Arctic. The settlement amount reflects OFAC’s determination that Cameron’s conduct was non-egregious and not voluntarily self- disclosed, and further reflects OFAC’s consideration of...
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1) BASIS FOR LIABILITY: SEEMINGLY PRECEDENTIAL STATEMENTS CONCERNING TRADITIONAL “FACILITATION” AS AN INDIRECT PROVISION OF “SERVICES” TO A SANCTIONS TARGET/“IN SUPPORT OF” A PROHIBITED DIRECTIVE 4 PROJECT
SSI Directive 4, as it existed as of the time of the alleged violations, provided in relevant part as follows, with emphasis added:
“…the following activities by a U.S. person or within the United States are prohibited…: the provision, exportation, or reexportation, directly or indirectly, of goods, services…or technology in support of exploration or production for deepwater, Arctic offshore, or shale projects that have the potential to produce oil in the Russian Federation, or in maritime area claimed by the Russian Federation and extending from its territory, and that involve any person determined to be subject to this Directive