The Department of Justice (“DOJ”) has announced that Schlumberger Oilfield Holdings (“SOHL”), a wholly-owned subsidiary of Schlumberger Ltd., agreed to enter a guilty plea and pay a $232,708,356 penalty for willfully facilitating illegal transactions and engaging in trade with Iran and Sudan.  The total penalty includes a $77,569,452 criminal forfeiture and an additional $155,138,904 criminal fine, representing the largest criminal fine in connection with a violation of the International Emergency Economic Powers Act (“IEEPA”).  The announcement indicated that although SOHL had policies in place to prevent one of its U.S. based business segments from violating U.S. Sanctions, it failed to train its employees adequately to ensure compliance.  As a result, the U.S. based segment violated sanctions against Iran and Sudan by approving and disguising capital expenditures requests from customers in Iran and Sudan, making and implementing business decisions concerning Iran and Sudan, and providing certain technical services and expertise regarding drilling tools and related equipment in Iran and Sudan.  Click here for the DOJ Release.