Must see: An opinion about N. Korea sanctions from an actual sanctions expert (really!)

William Newcomb, formerly of the U.S. Treasury Department and the U.N. Panel of experts (UNPOE), was at The Korea Society last Friday to talk with Stephen Noerper about North Korea sanctions, what they are, and how to make them a useful policy tool again.

Newcomb didn’t have time to explain all of the authorities and their provisions in detail, but he did make some important points.

First, Newcomb blames “politics” for the fact that the UNPOE hasn’t designated a number of “bad actors” that are violating the sanctions, and for the slowness of the UNPOE in obtaining the designation of Ocean Maritime Management. That delay was critical, because financial sanctions need to strand money to work, and after the 2013 seizure of the Chong Chon Gang in Panama, the North Koreans had plenty of scurry time after the light switch flicked on. It isn’t hard to see that Newcomb means China, although I can’t imagine Russia has played a constructive role.

Second, there are more bad actors that we could designate, but haven’t. Newcomb references the relatively small number of North Korean entities on the list of Specially Designated Nationals, something I’ve kvetched about for years now.

Third, Newcomb doesn’t think we have the equivalent of a Banco Delta Asia anymore—that is, a single point of failure that we can attack to cause instant disruption to Pyongyang’s palace economy. That’s not a shock to me, either, although I wonder if we’re even gathering the financial intelligence to know that for certain. After all, most North Korea transactions still don’t even require a license under 31 C.F.R. Part 510.

Certainly, some alternative points of failure come to my mind, but people in Pyongyang, Dar-as-Salaam, Nairobi, Kampala, Phnom Penh, and Ulan Bator read this site, so I’ll keep those thoughts to myself for now. Even so, the hard reality may well be that the North Koreans have squirreled away most of the low-hanging fruit. A financial constriction strategy will take longer to work today than it did in 2007 2005, but if implemented aggressively, it still shouldn’t take as long as it took us to bankrupt Osama bin Laden.