On 11 January, OFAC announced the settlement of $5,228,298 re the potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations. Sojitz (Hong Kong) made US dollar payments through US financial institutions for Iranian-origin high density polyethylene resin (HDPE) from its bank in Hong Kong to the HDPE supplier’s banks in Thailand.
https://home.treasury.gov/system/files/126/20220111_sojitz.pdf
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