Sojitz (Hong Kong) Limited — $5,228,298 OFAC penalty
OFAC published a $5,228,298 civil penalty against Sojitz (Hong Kong) Limited on 01/11/2022. It is the #52 largest action in OFAC’s 1,052-entry enforcement chart and #3 of the 14 actions published that year.
The record
| Entity, as published by OFAC | Sojitz (Hong Kong) Limited |
|---|---|
| Penalty / settlement amount | $5,228,298 |
| Date published by OFAC | 01/11/2022 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #52 of 1,052 |
| Rank within 2022 | #3 of 14 |
| Share of 2022 penalty total | 12.3% |
| Statutory maximum penalty | $151,545,831 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Non-egregious |
| Sanctions programs named in the release | Iran |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $151,545,831. The settled amount of $5,228,298 is 3.4% 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: 20220111_sojitz.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2022 actions
- Danfoss A/S — $4,379,810
- Toll Holdings Limited — $6,131,855
- CA Indosuez Switzerland S.A. — $720,258
- American Express National Bank — $430,500
- CFM Indosuez Wealth — $401,039
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