This settlement agreement (the "Settlement Agreement") with respect to ENF [redacted] is made by and between the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) and SCG Plastics Co., Ltd. ("SCG Plastics").

I. PARTIES

OFAC administers and enforces economic sanctions against targeted foreign countries, regimes, terrorists, international narcotics traffickers, and proliferators of weapons of mass destruction, among others. OFAC acts under Presidential national emergency authorities, as well as authority granted by specifi c legislation, to impose controls on transactions and freeze assets under U.S. jurisdiction.

SCG Plastics is a trading company headquartered in Bangkok, Thailand that purchased, marketed, and sold plastic resin products manufactured by subsidiaries and affiliates of its parent company, SCG Chemicals Co., Ltd. ("SCG Chemicals"). SCG Plastics is currently in the process of liquidation under the laws of Thailand.

Thai Polyethylene Co., Ltd. ("TPE") is a subsidiary of SCG Chemicals based in Thailand. In January 2022, SCG Plastics transferred all of its assets and existing liabilities to TPE for approximately $12.9 million. Following this entire business transfer in January 2022, all of these assets-including employees and sales activities-of SCG Plastics now reside at TPE. To help prevent any future violations of U.S. sanctions, and in furtherance of a settlement with OFAC addressing SCG Plastics' apparent violations of U.S. sanctions, TPE is agreeing to a set of sanctions compliance commitments pursuant to a separate agreement with OFAC (the "Compliance Agreement").

[...]