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Category: Sanctions

August 31, 2017

Do you own any clothing made in North Korea? (Answer: Don’t be so sure.)

The U.N. Security Council is reportedly considering a variety of new sanctions against North Korea over its latest missile test, and according to Reuters, a ban on textile exports is among the sanctions under consideration. For a few years, we’ve known that the export of textiles (or textile workers, who labor under sweatshop conditions for little or no pay) is increasingly lucrative for Pyongyang. I don’t need to explain that historically, textile work has lent itself to particularly exploitative labor...

Categories Human Trafficking/Sanctions
August 23, 2017

FBI, Treasury & DOJ hit N. Korean enablers with secondary sanctions, forfeitures

Two months ago, the Center for Advanced Defense Studies (C4ADS) released its groundbreaking report, “Risky Business,” which used open-source business records to trace the 5,233 companies that (according to C4ADS) comprise nearly the entirety of North Korea’s “limited, centralized, and vulnerable” financial networks in China. At the time, I speculated that we hadn’t heard the last word from the FBI, the Treasury Department, and Justice Department, and yesterday, my suspicions were confirmed. First, Treasury designated a series of North Korean, Chinese, and Russian...

Categories Arms Trafficking/Money Laundering/Sanctions
August 5, 2017

UNSCR 2371: Text and commentary (see update)

Today, the U.N. Security Council adopted Resolution 2371 unanimously. The text is in black, my commentary is in blue italic. PP1: Recalling its previous relevant resolutions, including resolution 825 (1993), resolution 1540 (2004), resolution 1695 (2006), resolution 1718 (2006), resolution 1874 (2009), resolution 1887 (2009), resolution 2087 (2013), resolution 2094 (2013), resolution 2270 (2016), resolution 2321 (2016), and resolution 2356 (2017), as well as the statements of its President of 6 October 2006 (S/PRST/2006/41), 13 April 2009 (S/PRST/2009/7) and 16...

Categories "United" Nations/Sanctions
August 1, 2017

Maximum pressure watch: North Korea, sanctions & diplomacy

The nature of human beings is to remember dramatic events longer than methodical processes, even when the methodical process may be of equal or greater importance. That may be why North Korea watchers remember the September 2005 action against Banco Delta Asia but tend to forget the greater part of the strategy that action served: sending Stuart Levey, Daniel Glaser, and other officials on a world tour to warn bankers and finance minister to cut their ties to Pyongyang or...

Categories Diplomacy/Sanctions
July 31, 2017

WaPo editors ask, “What if sanctions don’t work?” … and answer correctly.

Regular readers know by now how many keystrokes I’ve spent at this site and in print in various places citing the evidence that sanctions against North Korea were largely a sham until last year, and could work if we enforced them in earnest. Still, the editors of the Washington Post ask a question that even the most strident sanctions advocate must consider: ONE SCHOOL of North Korea experts has been arguing for some time that sanctions will never induce the...

Categories Sanctions
July 28, 2017

After a near miss in the Senate, the KIMS Act heads for the President’s desk

While the rest of you talk about missiles, I’m going to talk about responses. Last night, by a vote of 98 to 2, the Senate passed H.R. 3364, a bill imposing new sanctions against Russia, Iran,* and North Korea. The bill previously passed the House by a vote of 419 to 3, and now goes to the President’s desk. The North Korea sanctions are contained in Title III, which previously passed the House as the KIMS Act by a vote of...

Categories Sanctions/U.S. Law/U.S. Politics
July 24, 2017

OFK Exclusive: House, Senate move new North Korea sanctions legislation

Last year, Ed Royce, the Chairman of the House Foreign Affairs Committee, and Cory Gardner, Chairman of the Senate Asia Subcommittee, led the charge to cut Pyongyang’s access to the hard currency that sustains it by drafting and passing the North Korea Sanctions and Policy Enhancement Act. We’ve known all along that nothing short of presenting Kim Jong-Un with an existential choice — disarm and reform, or perish — would create the conditions for a negotiated disarmament of North Korea,...

Categories Arms Trafficking/Money Laundering/Sanctions/Shipping sanctions/U.S. Law
July 21, 2017

What construction in Pyongyang tells us, and doesn’t tell us, about sanctions

As the Trump administration looks to sanctions, including secondary sanctions, to gain the leverage to disarm North Korea, it is natural that North Korea watchers would try to gauge the potential for sanctions to impact Pyongyang’s finances. In a place where predictions of glasnost go to die, it is natural that they would measure what the regime puts on display, like the development of Pyongyang’s skyline. And regrettably, it is natural that any analysis whose research begins and ends with...

Categories Fiskings/Sanctions
July 12, 2017

Maximum pressure watch: The Dandong Zhicheng warrants foreshadow N. Korea-related indictments

Last fall, as America was consumed by (depending on your state of residence) post-election trauma or celebratory gunplay, China blew past the North Korean coal import caps it had just agreed to at the U.N., and the Obama administration issued what would be some of its final North Korea sanctions designations — of Daewon Industries (a coal exporter subordinate to the North Korean military) and Kangbong Trading Corporation (a coal exporter subordinate to the Munitions Industry Department and involved in the development of...

Categories Money Laundering/Sanctions/U.S. Law
July 5, 2017

We cannot live with a nuclear North Korea (or rather, it will not live with us)

Yesterday, the North Korean threat finally crossed the ocean to our shores. As it is after every fresh outrage from Pyongyang, the question many will ask is, “Now what?” Certainly, there are plenty of legal, financial, and diplomatic options on this list that President Trump’s cabinet can exercise. Congress is also ready to act, or nearly so. You should expect to see the Senate move legislation you’ve seen (or something similar to it) and legislation you have not yet seen....

Categories "United" Nations/Missiles/Proliferation/Sanctions/WMD
June 30, 2017

Commence Primary Ignition: Treasury zaps the Bank of Dandong for laundering Kim Jong-Un’s money

And so, the “maximum pressure” we’ve been waiting for begins in earnest. Yesterday afternoon, the Treasury Department announced a series of legal actions against Chinese enablers of North Korea’s proliferation, smuggling, and money laundering. First, Treasury’s Office of Foreign Assets Control froze the assets of two businessmen and a shipping company. One of those businessmen, Sun Wei, was the sole shareholder of Mingzheng International Trading, the Chinese company targeted in this recent civil forfeiture action. The shipping company was sanctioned for...

Categories Money Laundering/Sanctions
June 20, 2017

How to hold North Korea accountable for Otto Warmbier’s death

In North Korean prisons (at least, in those from which release is possible at all) when the guards conclude that a prisoner is about to die, they release her and send her away to die at home, so that disposing of her body will be someone else’s problem, and so that the warden can manipulate the camp’s rate of in-custody deaths downward. (Perhaps in some small way, even the wardens of North Korean prisons fear being held accountable, one day,...

Categories Foreigners in N. Korea/Sanctions/U.S. Law
June 15, 2017

Breaking: DOJ files $1.9M forfeiture complaint against North Korean front company in China

The U.S. Attorney for the District of Columbia issued a press release this afternoon announcing that it has filed a complaint under the civil forfeiture statute at 18 USC 981, to forfeit $1,902,976 from Mingzheng International Trading Limited of Shenyang, China. According to the complaint, Mingzheng conspired to evade sanctions and launder money through the United States on behalf of the Foreign Trade Bank of North Korea (FTB). Treasury designated the FTB under Executive Order 13382 in March 2013, for proliferation financing. Under the...

Categories Money Laundering/Proliferation/U.S. Law
June 15, 2017

Meet the fresh-faced kids who want you to commit a felony for Kim Jong-un

I confess that I’ve always hated Facebook, but every now and then, I see something there that interests me. One such example is the Facebook page of a group called Delegations for Dialogue, which led me to this slickly produced website. As it turns out, Delegations is run by a cast of improbably young characters promoting investment in North Korea through a “fact-finding†trip to Rason this August. Now, I suppose there are two kinds of people in this world...

Categories Money Laundering/Sanctions
June 13, 2017

C4ADS: Pyongyang’s networks in China are “centralized, limited, and vulnerable” to sanctions 

Because I’ve already given too many minutes of my life to the moveable farce named Dennis Rodman, I’m devoting today’s post to something more consequential: the Center for Advanced Defense Studies’s new report exposing more North Korean financial networks in China, and dispelling the misinformation that North Korea is isolated from the financial system and thus sanctions-proof. (Full disclosure: I advised C4ADS on the drafting of the report, without compensation of course.) Money quote: The continuing misperceptions of North Korea...

Categories China/Money Laundering/Sanctions/Shipping sanctions
June 8, 2017

China is cheating on the North Korea coal import ban (again) (with updates)

Via the indispensable Leo Byrne: Two North Korea-linked ships have arrived at two separate coal terminals in Shanghai since Sunday, while one other was departing the area after having left a third facility at a similar time. Satellite imagery shows that each of the terminals is equipped to handle coal. The UN currently restricts member states from importing North Korean coal, while Beijing has said numerous times that it has suspended all imports for the remainder of 2017. “Imagery indicates...

Categories China/Sanctions/Shipping sanctions
June 5, 2017

Trump & North Korea: In search of maximum pressure (Pt. 1)

Last week’s North Korea designations from the Treasury Department were the second round since Inauguration Day, and like the first round, they omitted the essential element for sanctions against North Korea to be effective: secondary sanctions to deter Chinese | banks and companies from enabling North Korean proliferation and money laundering, as they’ve been | doing for so long, and so flagrantly. On this point, I need not repeat Anthony Ruggiero’s arguments, so I’ll just refer you to his post. In other words,...

Categories "United" Nations/Money Laundering/Sanctions