OFAC Settles with Hong Kong Trading Company for $5.2 Million for Violations of Iran Sanctions Program | Michael Volkov

OFAC is off to a quick start in 2022.  After announcing its Airbnb enforcement action in the beginning of January, OFAC announced a settlement with Sojitz (Hong Kong) Limited, a Hong Kong, China-based company that engages in offshore trading and cross-border trade financing, for $5,228,298 for violations of the Iran Sanctions Program.

Sojitz HK violated the Iran Sanctions Program by making U.S. dollar payments through U.S. financial institutions for Iranian-origin high density polyethylene resin (HDPE) from its bank in Hong Kong to the HDPE supplier’s banks in Thailand.  By doing so, Sojitz HK caused the financial institutions that processed the funds to engage in prohibited financial transactions related to Iranian-origin goods.

Sojitz HK voluntarily disclosed the violations.

Between August 2016 and May 2018, Sojitz HK employees acted contrary to Sojitz HK’s policies and…