SCG Plastics Co., Ltd. — $20,000,000 OFAC penalty
OFAC published a $20,000,000 civil penalty against SCG Plastics Co., Ltd. on 04/19/2024. It is the #26 largest action in OFAC’s 1,052-entry enforcement chart and #1 of the 12 actions published that year.
What OFAC said
Co., Ltd. Settles with OFAC for $20,000,000 for Apparent Violations of the Iranian Transactions and Sanctions Regulations SCG Plastics Co., Ltd. ("SCG Plastics"), part of a multinational enterprise headquartered in Bangkok, Thailand that sells plastic resins, has agreed to pay $20,000,000 to settle its potential civil liability for 467 apparent violations of OFAC sanctions on Iran.
Quoted verbatim from OFAC’s enforcement release — read the original.
The record
| Entity, as published by OFAC | SCG Plastics Co., Ltd. |
|---|---|
| Penalty / settlement amount | $20,000,000 |
| Date published by OFAC | 04/19/2024 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #26 of 1,052 |
| Rank within 2024 | #1 of 12 |
| Share of 2024 penalty total | 41.0% |
| Apparent violations cited | 467 |
| Statutory maximum penalty | $600,399,124 |
| Voluntarily self-disclosed | No |
| OFAC egregiousness determination | Egregious |
| Sanctions programs named in the release | Iran |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $600,399,124. The settled amount of $20,000,000 is 3.3% of that maximum, which OFAC's Enforcement Guidelines tie to factors including voluntary self-disclosure and whether the conduct was egregious.
Primary source
OFAC enforcement release: 20240419_scgplastics.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2024 actions
- Aiotec GmbH — $14,550,000
- State Street Bank and Trust Company and its subsidiary, Charles River Systems, Inc. — $7,452,501
- EFG International AG — $3,740,442
- An Individual — $1,104,408
- Vietnam Beverage Company Limited — $860,000
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