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Company Settles With DOJ, OFAC and BIS Over Multiple Alleged Sanctions Violations

National Oilwell Varco entered into a $25 million non-prosecution agreement with the U.S. Attorney’s Office for the Southern District of Texas after the company allegedly violated Iranian and other sanctions regulations from about 2002 to 2009, the Office of Foreign Assets Control said (here). National Oilwell Varco also entered into settlements with OFAC and the Bureau of Industry and Security. Between October 2002 and April 2005, the company approved at least four payments totaling $2.63 million by its subsidiary Dreco Energy Services to a United Kingdom-based entity relating to the sale and exportation of goods, directly or indirectly, from Dreco to Iran, in apparent violation of the Iranian Transactions and Sanctions Regulations, OFAC said. The company also engaged in two transactions combining for nearly $13.6 million, involving the sale and exportation of goods to Iran, and/or facilitated those transactions in violation of the Iranian sanctions regulations.

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Between 2003 and 2007, Dreco knowingly exported goods from the U.S. to fill at least seven orders from Iranian customers totaling more than $526,480. Moreover, between 2007 and 2009, the subsidiary entered into 45 transactions worth a combined $1.7 million involving sale of goods to Cuba, in apparent violations of the Cuban Assets Control Regulations, OFAC said. The company cooperated with OFAC’s investigation and has made efforts to remediate its compliance program and agreed to further compliance enhancements, OFAC said. National Oilwell Varco’s roughly $6 million settlement with OFAC will be deemed satisfied by its payment of $25 million set forth in the company’s non-prosecution agreement with the USAO, OFAC said.