John S. Park of the Harvard Kennedy School thinks North Korea has …

become more adept at sanctions evasion, and sounds bearish about the prospects for success. I have no doubt that the first part of Park’s thesis is correct. I’m sure Pyongyang has diversified its income streams since Banco Delta Asia, which means that it will be harder to get back to where we were in 2005. On the other hand, I don’t think it will be impossible for sanctions to work, either. Al Qaeda, Iran, and the Medellin Cartel all have smart money launderers, and in the end, Treasury was effective against all of them. Unless North Korea has reinvented money laundering in ways that these targets haven’t, sanctions will work if given the appropriate investigative resources.

I’ll withhold judgment on the second part of Park’s thesis until I read it. I did contact Park to ask if he had published a paper or explained the basis for his views in detail, but so far, he hasn’t responded (he might be on his way back from Korea). I’ve read dozens of opinions that argued that sanctions haven’t worked against North Korea, but not one of those opinions showed much understanding of sanctions law, or how weak U.S. sanctions against North Korea really are. Without understanding the limitations of our current sanctions, or the extent of the authorities we still haven’t used, it’s impossible to understand their potential.