OFAC is a steady enforcement agency.  As the COVID-19 pandemic settled down, OFAC resumed aggressive enforcement of economic sanctions.  In its latest action, OFAC announced a settlement with Keysight Technologies (“Keysight”), a Santa Rosa, California, for conduct stemming from its former subsidiary, Anite Finland (“Anite”) for re-exports of US export-controlled test measurement equipment to Iran.  In a familiar fact pattern surrounding OFAC compliance and acquisitions,...