The structure itself is ordinary trade finance. It becomes a sanctions issue when one of the two credits belongs to a sanctioned party and the other is where the dollars move.
OFAC’s 2021 release on the French bank UBAF describes it exactly: a sanctioned Syrian entity was the beneficiary of an export credit or the applicant for an import credit that did not involve dollar clearing, “but the intermediary entered into or received one or more corresponding USD letters of credit to purchase or sell the same goods.” The sanctioned party’s side stayed outside the US financial system. The matching dollar credit did not. See the UBAF case.