The Treasury Department’s Office of Foreign Asset Control started off the new year with an interesting enforcement action against Airbnb Payments, Inc. (“Airbnb”), a money service business subsidiary of Airbnb, Inc. Airbnb agreed to pay $91,172.29 for violations of OFAC’s Cuban Sanctions Program.  Airbnb discovered the violations as a result of a proactive forensic review that was approved by OFAC.  Given the number of records...