SGC Plastics, headquartered in Bangkok, Thailand, to pay OFAC $20 million
23/04/2024
OFAC has entered into a settlement agreement ( https://ofac.treasury.gov/media/932841/download?inline ) with SGC Plastics, part of a multinational enterprise headquartered in Bangkok, Thailand, that sells plastic resins, in which SGC Plastics has agreed to pay $20 million to settle its potential civil liability for 467 apparent violations of OFAC sanctions on Iran.
According to the press release,
- From 2017 to 2018, SCG Plastics caused US financial institutions to process $291 million in wire transfers for sales of Iranian-origin high-density polyethylene resin (HDPE) manufactured by a joint venture in Iran owned by, among others, SCG Plastics’ parent company and the National Petrochemical Company of Iran (“NPC”), an entity that is part of Iranian Govt.
SCG Plastics allegedly obfuscated the products’ Iranian origin and Iranian parties’ involvement in shipping and payment documentation by listing the country of origin as the “Middle East” or Jebel Ali, UAE, rather than “Iran”.
Compliance considerations:
- This case highlights the risks of non-US companies using the US financial system to process transactions involving US-sanctioned persons or jurisdictions;
Aggravating factors for the penalty amount:
- SGC Plastics wilfully engaged in the concealment of the Iranian origin, conferred significant benefits on the Iranian Govt, and was commercially sophisticated at the time of the apparent violations; and
Mitigating factors for the penalty amount:
- SGC Plastics provided substantial cooperation to OFAC, SGC Plastics is in the process of undergoing liquidation, and TPE, the entity that has purchased SGC Plastics’ assets, has implemented multiple remedial measures to respond to the apparent violations, including adopting a sanctions compliance policy.
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.