Deal Diary

On January 31, 2017, Acting Chairman of the Securities and Exchange Commission (SEC), Michael S. Piwowar, issued two statements calling for comments on the SEC’s enforcement of the conflict minerals reporting requirements of the Dodd-Frank Act. Congress implemented the conflict minerals reporting requirements in an effort to reduce funding to armed groups that commit human rights abuses and contribute to conflict in the Democratic Republic of Congo (DRC).

In late March 2015, Schlumberger Oilfield Holdings Ltd. (SOHL), incorporated in the British Virgin Islands, agreed to plead guilty and pay a US$232.7 million penalty to the U.S. government for conspiracy to violate the International Emergency Economic Powers Act (IEEPA) by facilitating transactions in Iran and Sudan and exporting technical services involving these sanctioned countries. The penalty includes a US$155.1 million criminal fine, the largest IEEPA-related fine ever, as well as a US$77.6 million criminal forfeiture. The terms of the plea agreement also impose on SOHL a three-year period of corporate probation.