You’d be surprised how much tougher our Zimbabwe and Belarus sanctions are than our North Korea sanctions.

The Treasury Department has just tightened its sanctions regulations on … Zimbabwe, more than doubling the number of Zimbabwean entities on Treasury’s List of Specially Designated Nationals (called the SDN List) from 77 to 161, including “President” Robert Mugabe, his wife, and his son. The sanctions are largely directed at the Mugabe regime’s human rights violations, corruption, and subversion of the democratic process. Here, from Treasury’s Federal Register notice, is a summary of what those sanctions do:

Section 1(a) of E.O. 13469 blocks, with certain exceptions, all property and interests in property that are in the United States, that come within the United States, or that are or come within the possession or control of United States persons, including their overseas branches, of any person determined by the Secretary of the Treasury, after consultation with the Secretary of State: 

(i) To be a senior official of the Government of Zimbabwe;

(ii) to be owned or controlled by, directly or indirectly, the Government of Zimbabwe or an official or officials of the Government of Zimbabwe;

(iii) to have engaged in actions or policies to undermine Zimbabwe’s democratic processes or institutions;

(iv) to be responsible for, or to have participated in, human rights abuses related to political repression in Zimbabwe;

(v) to be engaged in, or to have engaged in, activities facilitating public corruption by senior officials of the Government of Zimbabwe;

(vi) to be a spouse or dependent child of any person whose property and interests in property are blocked pursuant to E.O. 13288, E.O. 13391, or E.O. 13469;

(vii) to have materially assisted, sponsored, or provided financial, material, logistical or technical support for, or goods or services in support of, the Government of Zimbabwe, any senior official thereof, or any person whose property and interests in property are blocked pursuant to E.O. 13288, E.O. 13391, or E.O. 13469; or

(viii) to be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to E.O. 13288, E.O. 13391, or E.O. 13469.

The property and interests in property of the persons described above may not be transferred, paid, exported, withdrawn, or otherwise dealt in. [79 Fed. Reg. at 39313]

Read together, the old and new rules effectively block all of Robert Mugabe’s closest relatives and key minions out of the global financial system, and specifically penalize (and therefore, deter) activities in furtherance of stealing public funds or votes, censoring free expression, or abusing the human rights of Zimbabweans.

Treasury’s new amendments to the Zimbabwe sanctions regulations tighten existing rules against facilitating or evading the existing sanctions, including a new requirement to obtain an OFAC license before donating food, clothing, or medicine to an entity on the SDN list. They even take the extraordinary step of blocking the assets of family members of those designated. Implicitly, they allow for the designation of entities that use non-dollar currencies to evade these sanctions, allowing for those enablers to be barred from the dollar system as well.

Our North Korea sanctions authorities consist of Executive Order 13466, in which President Bush lifted most of our previous sanctions but preserved some restrictions and the blocking of certain property; Executive Order 13551, which blocks the property of named entities involved in proliferation, weapons trafficking, and money laundering in a non-comprehensive way; Executive Order 13570, which imposes import sanctions; and regulations at 31 C.F.R. Part. 510. Now, how many of the above sanctions from the Zimbabwe regulations appear in North Korea-specific sanctions authorities? If you answered “none,” go get yourself a cookie.

This comparison chart, now slightly outdated, should give you the general idea — our North Korea sanctions are some of the weakest that we bother to maintain against any country. Note the empty squares indicating the lack of “comprehensive” or “financial” sanctions against North Korea, despite everything we’ve learned about how well they worked.

At the top of this post, I told you that 161 Zimbabwean entities are sanctioned. Wanna know how many are designated under North Korea-specific sanctions authorities? Seven. An additional 11 individuals and 25 entities are designated under Executive Order 13382, a Bush-era executive order that isn’t specific to North Korea, but authorizes sanctions against entities trafficking in WMD components and technology. I didn’t count, but it’s likely that most of those entities were designated during Bush’s first term. (I’ve pasted the full list of 43 designated North Korean entities below the fold.)

In case you’re wondering, no, Kim Jong Un, his royal family, and his senior government officials are not listed. The only sanctioned entities of any national consequence are Bureau 39 and the Foreign Trade Bank. The others are largely front companies, minor government ministries, and officials that are as easily replaced as whacked moles.

We can extend this comparison further. Slobodan Milosevic — a dead guy — still appears on the SDN List years after his death (presumably, to prevent the misuse of his estate’s assets). He is one of 231 “persons”* still designated under the Balkans sanctions program, two decades after the end of the Balkans wars. Treasury was so thorough in its targeting that it named many individual alleged war criminals by their nomes-de-guerre.

Alexander Lukashenko, the President of the neo-Soviet fossil state called Belarus, is one of about 50 “persons” designated under the Belarus sanctions program, along with his Justice Minister, KGB head, and the officials in charge of Belarus’s media and “elections.” Let no one say that the targeting of a head of state or a state’s top officials is unprecedented because sensitivities to the state’s powerful sponsor are too great.

The SDN List designates 164 “persons” as part of the Burma sanctions program, including Beijing-based China Focus Development Company. Let no one say that China’s economic links to its oppressive satellites are inviolable.

A whopping 397* “persons” are designated under the Cuba sanctions program, including what must be every website domain name registered in Cuba, and curiously, former Panamanian dictator Manuel Antonio Noriega. (Oddly enough, Fidel and Raul Castro are not designated.)

[*It’s likely that I counted a few aliases in these numbers.]

So many Iranian entities are listed – the number clearly runs into the hundreds – that I didn’t have the courage to count them all. Iran sanctions are clearly a small industry, but you can’t deny that Treasury’s focus has gotten results.

Hundreds of other targets are designated under Executive Order 13224, authorizing sanctions against terrorists, their sponsors, and their organizations.

Now, I’m no fan of Robert Mugabe, or any of these other regimes. I spent a few nervous days there in 1990 — and those were much better days for Zimbabweans — and the place certainly felt like a dictatorship. I don’t doubt that Mugabe deserves everything President Obama has dropped on him, but would anyone argue that Zimbabwe represents a strategic threat to the United States or to global peace? Or that its human rights abuses, however tragic, compare to the scale of those going on in North Korea?

When your list of sanctioned entities runs into the triple digits and you publish frequent updates to the list of Specially Designated Nationals, it means you’re serious about sanctioning your target. If, as in the case of North Korea, you’ve sanctioned a paltry three-and-a-half dozen over an entire damn decade, it means you aren’t. This, along with the Obama Administration’s utter inaction five months after the release of the U.N. Commission of Inquiry’s report, can only mean that President Obama is either disinterested in or unserious about addressing North Korea’s proliferation, money laundering, threats to peace, or crimes against humanity — even as he sanctions serious but less severe violations in Zimbabwe, Belarus, and other places.

North Korea-Specific, under EO 13551 (7)

1. BANK OF EAST LAND (a.k.a. DONGBANG BANK; a.k.a. TONGBANG BANK; a.k.a. TONGBANG U’NHAENG), PO Box 32, BEL Building, Jonseung-Dong, Moranbong District, Pyongyang, Korea, North; SWIFT/BIC BOEL KP PY [DPRK].
2. BUREAU 39 (a.k.a. CENTRAL COMMITTEE BUREAU 39; a.k.a. DIVISION 39; a.k.a. OFFICE #39; a.k.a. OFFICE 39; a.k.a. OFFICE NO. 39; a.k.a. “THIRD FLOOR”), Second KWP Government Building (Korean – Ch’o’ngsa), Chungso’ng, Urban Town (Korean – Dong), Chung Ward, Pyongyang, Korea, North; Chung-Guyok (Central District), Sosong Street, Kyongrim-Dong, Pyongyang, Korea, North; Changgwang Street, Pyongyang, Korea, North [DPRK].
3. DAESONG TRADING (a.k.a. DAESONG TRADING COMPANY; a.k.a. KOREA DAESONG GENERAL TRADING CORPORATION; a.k.a. KOREA DAESONG TRADING COMPANY; a.k.a. KOREA DAESONG TRADING CORPORATION), Pulgan Gori Dong 1, Potonggang District, Pyongyang City, Korea, North; PHONE 850 2 18111 8204/8208; PHONE 850 2 381 8208/4188; FAX 850 2 381 4431/4432; EMAIL daesong@co.chesin.com [DPRK].
4. GREEN PINE ASSOCIATED CORPORATION (a.k.a. CHO’NGSONG UNITED TRADING COMPANY; a.k.a. CHONGSONG YONHAP; a.k.a. CH’O’NGSONG YO’NHAP; a.k.a. CHOSUN CHAWO’N KAEBAL T’UJA HOESA; a.k.a. JINDALLAE; a.k.a. KU’MHAERYONG COMPANY LTD; a.k.a. NATURAL RESOURCES DEVELOPMENT AND INVESTMENT CORPORATION; a.k.a. SAENGP’IL COMPANY), c/o Reconnaissance General Bureau Headquarters, Hyongjesan-Guyok, Pyongyang, Korea, North; Nungrado, Pyongyang, Korea, North [DPRK].
5. KIM, Yong Chol (a.k.a. KIM, Yong-Chol; a.k.a. KIM, Young-Cheol; a.k.a. KIM, Young-Chol; a.k.a. KIM, Young-Chul); DOB circa 1947; alt. DOB circa 1946; POB Pyongan-Pukto, North Korea (individual) [DPRK].
6. KOREA DAESONG BANK (a.k.a. CHOSON TAESONG UNHAENG; a.k.a. TAESONG BANK), Segori-dong, Gyongheung St., Potonggang District, Pyongyang, Korea, North; SWIFT/BIC KDBK KP PY; PHONE 850 2 381 8221; PHONE 850 2 18111 ext. 8221; FAX 850 2 381 4576; TELEX 360230 and 37041 KDP KP; TGMS daesongbank; EMAIL kdb@co.chesin.com [DPRK].
7. RECONNAISSANCE GENERAL BUREAU (a.k.a. CHONGCH’AL CH’ONGGUK; a.k.a. KPA UNIT 586; a.k.a. “RGB”), Hyongjesan-Guyok, Pyongyang, Korea, North; Nungrado, Pyongyang, Korea, North [DPRK].

WMD Sanctions under EO 13382 (36)

1. 2ND ACADEMY OF NATURAL SCIENCES (a.k.a. ACADEMY OF NATURAL SCIENCES; a.k.a. CHAYON KWAHAK-WON; a.k.a. CHE 2 CHAYON KWAHAK-WON; a.k.a. KUKPANG KWAHAK-WON; a.k.a. NATIONAL DEFENSE ACADEMY; a.k.a. SANSRI; a.k.a. SECOND ACADEMY OF NATURAL SCIENCES; a.k.a. SECOND ACADEMY OF NATURAL SCIENCES RESEARCH INSTITUTE), Pyongyang, Korea, North [NPWMD].
2. CHANG, Myong-Chin (a.k.a. JANG, Myong-Jin); DOB 1966; alt. DOB 1965 (individual) [NPWMD].
3. CHANGGWANG CREDIT BANK (f.k.a. KOREA CHANGGWANG CREDIT BANK; a.k.a. TANCHON COMMERCIAL BANK), Saemul 1-Dong Pyongchon District, Pyongyang, Korea, North [NPWMD].
4. CHANGGWANG SINYONG CORPORATION (a.k.a. EXTERNAL TECHNOLOGY GENERAL CORPORATION; a.k.a. KOREA KUMRYONG TRADING COMPANY; a.k.a. KOREA MINING DEVELOPMENT TRADING CORPORATION; a.k.a. NORTH KOREAN MINING DEVELOPMENT TRADING CORPORATION; a.k.a. “KOMID”), Central District, Pyongyang, Korea, North [NPWMD].
5. CHOSON INTERNATIONAL CHEMICALS JOINT OPERATION COMPANY (a.k.a. CHOSUN INTERNATIONAL CHEMICALS JOINT OPERATION COMPANY; a.k.a. INTERNATIONAL CHEMICAL JOINT VENTURE CORPORATION; a.k.a. KOREA INTERNATIONAL CHEMICAL JOINT VENTURE COMPANY), Hamhung, South Hamgyong Province, Korea, North; Man gyongdae-kuyok, Pyongyang, Korea, North; Mangyungdae-gu, Pyongyang, Korea, North [NPWMD].
6. CHOSUN YUNHA MACHINERY JOINT OPERATION COMPANY (a.k.a. KOREA RYENHA MACHINERY J/V CORPORATION; a.k.a. KOREA RYONHA MACHINERY JOINT VENTURE CORPORATION; a.k.a. RYONHA MACHINERY JOINT VENTURE CORPORATION), Mangungdae-gu, Pyongyang, Korea, North; Mangyongdae District, Pyongyang, Korea, North; Central District, Pyongyang, Korea, North [NPWMD].
7. CHU, Kyu-Chang (a.k.a. CHU, Kyu-Ch’ang; a.k.a. JU, Kyu-Chang); DOB 25 Nov 1928; POB Hamju County, South Hamgyong Province, Democratic People’s Republic of Korea (individual) [NPWMD].
8. COMMITTEE FOR SPACE TECHNOLOGY (a.k.a. DEPARTMENT OF SPACE TECHNOLOGY OF NORTH KOREA; a.k.a. DPRK COMMITTEE FOR SPACE TECHNOLOGY; a.k.a. KCST; a.k.a. KOREAN COMMITTEE FOR SPACE TECHNOLOGY), Pyongyang, Korea, North [NPWMD].
9. DAEDONG CREDIT BANK (a.k.a. DAE-DONG CREDIT BANK; a.k.a. DCB; a.k.a. TAEDONG CREDIT BANK), Suite 401, Potonggang Hotel, Ansan-Dong, Pyongchon District, Pyongyang, Korea, North; Ansan-dong, Botongang Hotel, Pongchon, Pyongyang, Korea, North; SWIFT/BIC DCBK KPPY [NPWMD].
10. DCB FINANCE LIMITED, Akara Building, 24 de Castro Street, Wickhams Cay I, Road Town, Tortola, Virgin Islands, British; Dalian, China [NPWMD].
11. FOREIGN TRADE BANK OF THE DEMOCRATIC PEOPLE’S REPUBLIC OF KOREA (a.k.a. NORTH KOREA’S FOREIGN TRADE BANK), FTB Building, Jungsong-dong, Central District, Pyongyang, Korea, North; SWIFT/BIC FTBD KP PY [NPWMD].
12. GENERAL BUREAU OF ATOMIC ENERGY (a.k.a. GBAE; a.k.a. GENERAL DEPARTMENT OF ATOMIC ENERGY), Haeudong, Pyongchen District, Pyongyang, Korea, North [NPWMD].
13. HESONG TRADING CORPORATION, Pyongyang, Korea, North [NPWMD].
14. KIM, CHIN-SO’K (a.k.a. KIM, TONG MYONG; a.k.a. KIM, TONG-MYO’NG; a.k.a. “KIM, JIN SOK”), c/o Tanchon Commercial Bank, Saemul 1-Dong Pyongchon District, Pyongyang, Korea, North; DOB 1964; nationality Korea, North (individual) [NPWMD].
15. KIM, Chol Sam; DOB 11 Mar 1971; nationality Korea, North; Treasurer, Daedong Credit Bank (individual) [NPWMD].
16. KIM, Kwang-Il, Beijing, China; nationality Korea, North; Tanchon Commercial Bank Deputy Representative to Beijing, China (individual) [NPWMD].
17. KO, Ch’o’l-Chae, Dalian, China; nationality Korea, North; Deputy Representative, KOMID (individual) [NPWMD].
18. KOREA COMPLEX EQUIPMENT IMPORT CORPORATION, Rakwon-dong, Pothonggang District, Pyongyang, Korea, North [NPWMD].
19. KOREA HEUNGJIN TRADING COMPANY (a.k.a. HUNJIN TRADING CO.), Pyongyang, Korea, North [NPWMD].
20. KOREA HYOKSIN EXPORT AND IMPORT CORPORATION (a.k.a. KOREA HYOKSIN TRADING CORPORATION), Rakwon-dong, Pothonggang District, Pyongyang, Korea, North [NPWMD].
21. KOREA KWANGSON BANKING CORP (a.k.a. KKBC), Jungson-dong, Sungri Street, Central District, Pyongyang, Korea, North [NPWMD].
22. KOREA KWANGSONG TRADING CORPORATION, Rakwon-dong, Pothonggang District, Pyongyang, Korea, North [NPWMD].
23. KOREA PUGANG TRADING CORPORATION, Rakwon-dong, Pothonggang District, Pyongyang, Korea, North [NPWMD].
24. KOREA RYENGWANG TRADING CORPORATION (a.k.a. KOREA RYONGWANG TRADING CORPORATION), Rakwon-dong, Pothonggang District, Pyongyang, Korea, North [NPWMD].
25. KOREA RYONBONG GENERAL CORPORATION (a.k.a. KOREA YONBONG GENERAL CORPORATION; f.k.a. LYONGAKSAN GENERAL TRADING CORPORATION), Pot’onggang District, Pyongyang, Korea, North; Rakwon-dong, Pothonggang District, Pyongyang, Korea, North [NPWMD].
26. KOREA TAESONG TRADING COMPANY, Pyongyang, Korea, North [NPWMD].
27. KOREA TANGUN TRADING CORPORATION, Pyongyang, Korea, North [NPWMD].
28. MILITARY SUPPLIES INDUSTRY DEPARTMENT (a.k.a. MUNITIONS INDUSTRY DEPARTMENT), Pyongyang, Korea, North [NPWMD].
29. MUN, Cho’ng-Ch’o’l, C/O Tanchon Commercial Bank, Saemaeul 1-Dong, Pyongchon District, Pyongyang, Korea, North; nationality Korea, North; Tanchon Commercial Bank Representative (individual) [NPWMD].
30. NAM CHON GANG CORPORATION (a.k.a. NAMCHONGANG TRADING; a.k.a. NAMCHONGANG TRADING CORPORATION; a.k.a. NOMCHONGANG TRADING CO.; a.k.a. “NCG”), Pyongyang, Korea, North [NPWMD].
31. RI, Che-Son (a.k.a. RI, Je-Son), c/o General Bureau of Atomic Energy, Haeudong, Pyongchen District, Pyongyang, Korea, North; DOB 1938; nationality Korea, North (individual) [NPWMD].
32. RI, Hong-Sop, c/o General Bureau of Atomic Energy, Haeudong, Pyongchen District, Pyongyang, Korea, North; DOB 1940; nationality Korea, North (individual) [NPWMD].
33. SECOND ECONOMIC COMMITTEE, Kangdong, Korea, North [NPWMD].
34. TOSONG TECHNOLOGY TRADING CORPORATION, Pyongyang, Korea, North [NPWMD].
35. YO’N, Cho’ng-Nam, Dalian, China; nationality Korea, North; Chief Representative, KOMID (individual) [NPWMD].
36. YUN, Ho-Chin (a.k.a. YUN, Ho-Jin), c/o Namchongang Trading Corporation, Pyongyang, Korea, North; DOB 13 Oct 1944; nationality Korea, North (individual) [NPWMD].