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Financial Services Law Insights and Observations

OFAC sanctions DPRK cyber and IT workers

Financial Crimes Of Interest to Non-US Persons Department of Treasury OFAC OFAC Designations OFAC Sanctions SDN List North Korea

Financial Crimes

On May 23, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order (E.O.) 13687 and E.O. 13810, against four entities and one individual, involved in obscure revenue generation and malicious cyber activities supporting the Democratic People’s Republic of Korea (DPRK) government. Through continued coordination with the Republic of Korea (ROK), one individual and one of the entities are concurrently being sanctioned by the ROK, while the other three entities OFAC designated were previously sanctioned by the ROK earlier in February. According to OFAC, the malicious cyber action and illicit IT worker revenue generation supports the DPRK’s unlawful weapons of mass destruction and ballistic missile programs. As a result of the sanctions, all property and interests in property of the designated persons that are in the United States, or in the possession or control of U.S. persons, are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. OFAC further mentioned, “any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the individuals or entities designated today could be subject to U.S. correspondent or payable-through account sanctions.”