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Exception Tracking Spreadsheet (TicklerTrax™)
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OFAC settles with Hong Kong company for $5M+

On Tuesday, OFAC announced a settlement with Sojitz (Hong Kong) Limited ("Sojitz HK"), a Hong Kong, China-based company that engages in offshore trading and cross-border trade financing. Sojitz HK agreed to remit $5,228,298 to settle its potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR).

In its Enforcement Release, OFAC said that this case "demonstrates the importance of effective risk-based internal controls to identify, interdict, escalate, and prevent activity prohibited by the sanctions programs administered by OFAC. Even where elements of a reasonable compliance program are in place, employees may act on their own initiative to pursue profit over compliance and find ways to circumvent their organization’s policies and procedures. In such cases, their actions can result in violations attributable to their organizations. This case also highlights the risks and potential costs that non-U.S. companies are exposed to when the U.S. financial system is used for transactions that may involve sanctioned persons or jurisdictions."

Details of the Sojitz HK conduct that led to the settlement can be found in the January 11, 2022, BankersOnline Penalty page.

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