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...