The Office of Foreign Assets Control (“OFAC”) has demonstrated its ability to multi-task — designing, implementing and enforcing a comprehensive sanctions regime against Russia after its invasion of Ukraine, and maintaining its “regular” enforcement program. In a recent two-fisted settlement, OFAC reached two separate settlements with Credit Agricole companies.  First, OFAC reached a settlement with Credit Indosuez Switzerland S.A. (“CAIS”), an indirect subsidiary of Swiss-based...