The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today 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). The apparent violations occurred when Sojitz HK made U.S. dollar payments through U.S. financial institutions for Iranian-origin high density polyethylene resin (HDPE) from its bank in Hong Kong to the HDPE supplier’s banks in Thailand. In doing so, Sojitz HK caused the U.S. financial institutions that processed the funds to engage in and facilitate prohibited financial transactions related to goods of Iranian origin. The settlement amount reflects OFAC’s determination that Sojitz HK’s apparent violations were non-egregious and voluntarily self-disclosed, and accounts for Sojitz HK’s remedial response and cooperation with OFAC.