This page describes why a jurisdiction appears in published enforcement records and typology reports. It is not an assessment of the country, its government or its businesses. Every jurisdiction listed here is a substantial legitimate economy, and appearing in this reference is usually a consequence of trade volume and connectivity rather than of weak rules.
Why it appears
Both Thai entries concern the same product, high-density polyethylene made in Iran, resold through a Thai trading company or supplier to buyers elsewhere in Asia. They also share a legal hook: the exposure arose not from the resin itself but from the use of US dollars and US banks to settle the sales.
In the record
SCG Plastics, a trading company in a group headquartered in Bangkok, paid OFAC $20 million in 2024. Customers in East Asia were told to pay in dollars into its accounts in Thailand, and OFAC found 457 such payments worth $289.3 million passed through US correspondent banks in 2017 and 2018. The shipping and payment documents gave the origin as “Middle East” instead of Iran.
Sojitz Hong Kong paid $5,228,298 in 2022 after it bought Iranian-origin polyethylene from a supplier in Thailand, for resale to buyers in China, and paid for it by dollar wire through US banks.
Reading it correctly
Neither case alleges that Thailand’s rules were weak or that the Thai companies hid a scheme from their own authorities. The exposure was created by the currency and the clearing route. The pattern is on the correspondent banking and third-country transshipment technique pages, and the point for a screening team is that a country of origin written as a region (“Middle East”) is a data-quality failure that a document check can catch.