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  • OFAC targets Singaporean persons for assisting North Korea in evading U.S. sanctions

    Financial Crimes

    On October 25, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it made three additions to the Specially Designated Nationals (SDNs) List pursuant to Executive Order 13551, which empowers the United States to block the property of certain persons with respect to North Korea. OFAC said the decision was designed to reinforce the U.S.’s ongoing “commitment to safeguard the international financial system and implement existing UN Security Council [ ] resolutions.” OFAC’s additions identify one Singaporean individual and two Singapore-based entities found to have helped North Korea evade U.S. sanctions—either directly or indirectly—by allegedly engaging in money laundering, counterfeiting goods or currency, smuggling bulk cash, trafficking narcotics, or engaging in other forms of illicit economic activity involving or supporting the North Korean government or any senior official. As a result, all assets belonging to the identified individual and entities subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.

    In a related action, the DOJ unsealed a federal indictment against the Singaporean individual who was charged with fulfilling millions of dollars in commodities contracts for North Korea and defrauding several financial institutions in hiding those illicit transactions using international front companies, including entities previously identified as SDNs for supporting the North Korean regime’s illicit activities. The indictment’s charges include conspiracies to (i) violate international sanctions; (ii) commit bank fraud; (iii) commit money laundering; and (iv) defraud the U.S. The charges also include counts of bank fraud and money laundering.

    See here for previous InfoBytes coverage on North Korean sanctions.

    Financial Crimes Department of Treasury OFAC North Korea Sanctions

  • OFAC adds North Korea-controlled information technology companies in China and Russia to Specially Designated Nationals List

    Financial Crimes

    On September 13, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it made additions to the Specially Designated Nationals List pursuant to Executive Order (E.O.) 13722 and E.O. 13810. These additions identify one individual and two entities connected to illicit revenue earned by North Korea from overseas information technology (IT) workers. According to OFAC, the China and Russia-based front companies were actually managed and controlled by North Koreans, while the designated North Korean individual acted on behalf of the Chinese company. All designees were purported to have (i) “engaged in, facilitated, or been responsible for the exportation of workers from North Korea, including exportation to generate revenue for the Government of North Korea or the Workers’ Party of Korea”; and (ii) operated in the North Korean IT industry. As a result, all assets belonging to the identified individual and entities subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.

    See here for previous InfoBytes coverage on North Korean sanctions.

    Financial Crimes OFAC Department of Treasury Sanctions North Korea China

  • OFAC adds North Koreans to Specially Designated Nationals List

    Financial Crimes

    On September 6, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) made additions to the Specially Designated Nationals List pursuant to Executive Order (E.O.) 13722. OFAC’s additions to the designations identify one individual and one entity found to have “engaged in significant activities undermining cybersecurity through the use of computer networks or systems against targets outside of North Korea” on behalf of the Government of North Korea. OFAC cites to the individual’s participation in a 2016 cyber-enabled fraudulent transfer of $81 million, a 2017 ransomware attack, and the 2014 cyber-attack against a U.S. entertainment company. As a result, all assets belonging to the identified individual and entity subject to U.S. jurisdiction are blocked and must be reported to OFAC, and U.S. persons are generally prohibited from engaging in transactions with them.

    See here for previous InfoBytes coverage on North Korean sanctions.

    Financial Crimes OFAC Department of Treasury International North Korea Sanctions Executive Order

  • OFAC targets shipping industry in expanded North Korea sanction

    Financial Crimes

    On August 15, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) imposed additional sanctions, pursuant to Executive Order 13810, designed to reinforce the U.S.’s ongoing commitment to prevent the financing of North Korea’s weapons of mass destruction programs and activities. The sanctions designate a Chinese-based trading company and its Singaporean-based affiliate, along with a Russian-based port service agency and its director general, for allegedly facilitating illicit shipments on behalf of North Korea. Pursuant to OFAC’s sanctions, all property and interests in property of the designated persons within U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from participating in transactions with these persons. 

    See here for previous InfoBytes coverage on North Korean sanctions.

    Financial Crimes OFAC Department of Treasury North Korea Sanctions International

  • OFAC targets facilitators of illicit North Korean financial transactions; Russian bank sanctioned

    Financial Crimes

    On August 3, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced its decision to sanction a Russian bank, pursuant to Executive Order (E.O.) 13810, for allegedly “knowingly facilitating a significant transaction” on behalf of an individual connected to North Korea’s primary foreign exchange bank. According to OFAC, the Russian bank violated its UN Security Council (UNSC) obligations by providing banking services to a representative of the North Korean bank who had previously been designated for weapons of mass destruction-related activities connected to North Korea. OFAC also issued sanctions against the North Korean bank’s Moscow-based deputy representative (E.O. 13687), as well as two of its associated “front companies” (E.O. 13722) accused of facilitating North Korean illicit financial activity. OFAC noted that, in accordance with UNSC requirements, all identified representatives “working on behalf of or at the direction of a [North Korean] bank or financial institution” should have been expelled from Russia, but instead, the Russian bank continued to facilitate transactions with the sanctioned persons. Pursuant to OFAC’s sanctions, all property and interests in property of the designated persons within U.S. jurisdiction are blocked and “may not be transferred, paid, exported, withdrawn, or otherwise dealt in.” Moreover, U.S. persons are “generally prohibited” from participating in transactions with these individuals and entities. 

    See here for previous InfoBytes coverage on North Korean sanctions.

    Financial Crimes OFAC Department of Treasury Russia North Korea Sanctions

  • Departments of Treasury, State, and Homeland Security issue joint advisory warning businesses of North Korean sanctions evasion tactics

    Financial Crimes

    On July 23, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), in conjunction with the Department of State and the Department of Homeland Security, issued an advisory to warn businesses—including manufacturers, buyers, and service providers—of the potential risks that may result from sanctions evasion tactics used by North Korea across supply chains. The advisory also provides assistance for businesses complying with Title III of the Countering America’s Adversaries Through Sanctions Act of 2017 with respect to North Korean sanctions. According to the advisory, the U.S. government “is focusing its disruption efforts on North Korean citizens or nationals whose labor generates revenue for the North Korean government.” Specifically, the advisory warns businesses to examine their entire supply chains and adopt appropriate, well-documented due diligence best practices, which “may be considered mitigating factors when the U.S. government determines the appropriate enforcement response.” The advisory also outlines penalties for violations of sanctions and enforcement actions.

    See here for previous InfoBytes coverage on North Korea sanctions.

    Financial Crimes Department of Treasury Department of State Department of Homeland Security Sanctions CAATSA North Korea OFAC

  • OFAC reissues North Korean Sanctions Regulations

    Financial Crimes

    On March 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published a final rule in the Federal Register to amend and reissue the North Korea Sanctions Regulations in their entirety. The final rule implements Executive Orders 13687, 13722, and 13810, references the North Korea Sanctions and Policy Enhancement Act of 2016 and the Countering America’s Adversaries Through Sanctions Act of 2017, and provides the Treasury Secretary, “in consultation with the Secretary of State, additional tools to disrupt North Korea’s ability to fund its weapons of mass destruction and ballistic missile programs.” All property and interests in property of the Government of North Korea and the Workers’ Party of Korea are blocked, transactions by U.S. persons involving the sanctioned entities are generally prohibited, and “all transactions within the United States, including all financial transactions that transit the U.S. financial system, must comply with OFAC regulations.” Among other things, the final rule (i) incorporates several general licenses previously only available on OFAC’s North Korea Sanctions page; (ii) adds several new general licenses; (iii) adds and expands provisions to provide the public with a more comprehensive set of regulations; (iv) updates certain regulatory provisions; and (v) makes other technical and conforming changes. The final rule takes effect March 5, 2018. Also released the same day were updates to OFAC’s North Korea-related FAQs.

    See here for previous InfoBytes coverage on North Korean sanctions.

    Financial Crimes OFAC Sanctions International Department of Treasury CAATSA

  • OFAC sanctions target North Korea’s shipping and trading industry

    Financial Crimes

    On February 23, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) imposed additional sanctions targeting the North Korean shipping and trading industry. The sanctions include the designation of 27 entities, 28 vessels, and one individual consistent with the Countering America’s Adversaries Through Sanctions Act of 2017. Treasury Secretary Steven T. Mnuchin stated, “Treasury is aggressively targeting all illicit avenues used by North Korea to evade sanctions, including taking decisive action to block the vessels, shipping companies, and entities across the globe that work on North Korea’s behalf. This will significantly hinder the Kim regime’s capacity to conduct evasive maritime activities that facilitate illicit coal and fuel transports, and erode its abilities to ship goods through international waters.” All property or interests in property held by the sanctioned individual and entities within U.S. jurisdiction must be blocked, and transactions between the designated persons and Americans are also prohibited.

    Separately, OCAC issued a global shipping advisory in conjunction with the U.S. Department of State and the U.S. Coast Guard to, among other things, (i) outline methods employed by North Korea to facilitate illicit transactions to evade sanctions; (ii) list due diligence steps companies should employ to monitor illicit North Korean activity and mitigate the risk of potentially engaging in prohibited activity or transactions; and (iii) provide an overview of penalties associated with violating U.S. or UN sanctions.

    See here for previous InfoBytes coverage on North Korean sanctions.

    Financial Crimes OFAC Sanctions CAATSA International Department of Treasury

  • OFAC continues to expand North Korean sanctions

    Financial Crimes

    On January 24, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) imposed additional sanctions in response to North Korea's ongoing weapons development programs, continued sanctions evasions, and United Nations Security Council Resolutions violations. The sanctions were issued against nine entities, 16 individuals, and six vessels pursuant to Executive Orders 13810 or 13687. Five of the sanctioned individuals have links to North Korean financial networks, with several of the individuals in possession of accounts held at Chinese banks. All property held by the sanctioned individuals and entities within U.S. jurisdiction was frozen, and transactions between the sanctioned individuals and entities and Americans are also prohibited.

    See here for previous InfoBytes coverage on North Korean sanctions.

    Financial Crimes Department of Treasury OFAC Sanctions International

  • OFAC amends Iraq Stabilization and Insurgency Sanctions Regulations, sanctions additional North Koreans

    Financial Crimes

    On December 27, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) released amendments to its Iraq Stabilization and Insurgency Sanctions Regulations (ISISR) to implement Executive Order 13668 (“Ending Immunities Granted to the Development Fund for Iraq and Certain Other Iraqi Property and Interests in Property Pursuant to Executive Order 13303, as Amended”). Previously, the ISISR prohibited and deemed null and void “any attachment, judgment, decree, lien, execution, garnishment, or other judicial process” related to (i) the sale and marketing of petroleum and petroleum products involving U.S. persons; and (ii) “any accounts, assets, investments, or any other property of any kind owned by, belonging to, or held by the Central Bank of Iraq, or held, maintained, or otherwise controlled by any financial institution of any kind in the name of, on behalf of, or otherwise for the Central Bank of Iraq.” OFAC’s amendments remove these prohibitions, and also implement technical and conforming changes. The amendments took effect December 28.

    Separately, on December 26, OFAC announced that two North Korean individuals have been added to the Specially Designated Nationals List. Assets belonging to individuals on the list are blocked, and transactions by U.S. persons involving these individuals or that are otherwise subject to U.S. jurisdiction are also generally prohibited. See here for previous InfoBytes coverage on North Korean sanctions.

    Financial Crimes Department of Treasury OFAC Sanctions International

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