by Jeremy Paner
Over the past few months, the United States government has relied upon its economic sanctions and anti-money laundering authorities to increase pressure on North Korea and its sponsor China. Treasury’s Office of Foreign Assets Control (OFAC), Financial Crimes Enforcement Network (FinCEN), and the State Department have all recently contributed to this effort. Examples from earlier this month include the redesignation of North Korea as a State Sponsor of Terrorism following Secretary Tillerson’s determination that North Korea “has repeatedly provided support for acts of international terrorism,” FinCEN’s Final Rule imposing prohibitions against China’s Bank of Dandong for its alleged sanctions evasion on behalf of North Korea, and OFAC’s designations and identifications of blocked property pursuant to Executive Order 13810.
Irrespective of the press releases announcing these sanctions, the most significant actions by the U.S. government have likely occurred behind the scenes in partnership with financial institutions and foreign partners. This information sharing with non-U.S. regulators and confidential targeted financial intelligence gathering against North Korean cover companies will likely steadily increase for the foreseeable future. Continue reading