A precise illustration of how origin, not identity, can be the thing that makes a transaction prohibited.
OFAC’s enforcement release describes trading between August 2016 and May 2018 in which Sojitz Hong Kong bought approximately 64,000 tons of Iranian-origin high density polyethylene from a supplier in Thailand for resale to buyers in China, paying the purchase price by wire transfer to the Thai supplier on shipment.
None of the parties to those payments was Iranian. The buyer was in Hong Kong, the supplier was in Thailand, the ultimate customers were in China. What brought the transactions within the prohibition was that the goods were of Iranian origin and the payments passed through US financial institutions, which were thereby caused to facilitate prohibited transactions in Iranian-origin goods.
The lesson for screening
Sanctions screening looks at parties. This transaction had no party to find. The restricted element was a property of the cargo, recorded in trade documents that the paying banks never saw.
That is the structural reason origin-based restrictions are harder to enforce through the payment system than party-based ones, and the reason origin documentation attracts the attention it does.
The outcome
OFAC determined the apparent violations were non-egregious and voluntarily self-disclosed, and the settlement reflects Sojitz HK’s remedial response and cooperation — the mitigation profile that self-disclosure produces, and a useful contrast with the British American Tobacco settlement.