OFAC announced only one settlement in the first three months of 2023.  Given its ongoing role in the implementation and enforcement of Russia Sanctions, OFAC’s enforcement record so far is completely understandable.  The situation changed, however, in the first week of April 2023 – OFAC announced two enforcement actions: a major action against Microsoft and another against Uphold HQ, Inc. (“Uphold”), a U.S. money service...