Category: Money Laundering

Due to a convergence of other commitments, it took me longer than I’d hoped to digest the U.N. Panel of Experts‘s latest findings about North Korea and financial sanctions. If you only read the bottom line and stop there, you’ll either be discouraged or find support for an argument that sanctions are futile. 210. Despite expanded financial sanctions adopted by the Security Council in resolutions 2270 (2016) and 2321 (2016), the Democratic People’s Republic of Korea has continued to access...

Years from today, North Korean bankers will remember 2016 as their annus horribilis. In February, a month after the North’s fourth nuclear test, Congress passed, and the President signed, the North Korea Sanctions and Policy Enhancement Act. Section 201 of the new law all but compelled the Treasury Department to designate North Korea a Primary Money Laundering Concern under section 311 of the Patriot Act. Section 311 allows for a menu of special measures to protect the financial system against...

After a long delay, the Treasury Department has issued its final rule prohibiting financial institutions operating in U.S. jurisdiction from providing direct or indirect correspondent account services to North Korean financial institutions. In English, that means North Korean banks are now denied a critical link for accessing the global financial system. North Korea is now one of only three countries to be declared a Primary Money Laundering Concern by the Treasury Department, and is the only country subject to Special Measure...

It has now been an inexplicably long four months since the Treasury Department announced its Notice of Proposed Rulemaking to designate North Korea as a jurisdiction of primary money laundering concern, in which it stated its intent to cut off North Korean banks’ access to correspondent accounts in the dollar financial system. Under section 311 of the Patriot Act, however, such a cutoff only becomes legally enforceable after Treasury publishes its final rule, which Treasury still has not done, and...

As I write today, rumors are swirling through the South Korean media of defections and purges involving so many North Korean diplomats, spies, minders, workers, and other officials that I haven’t had the time to either keep up with them or sort out the conflicts in those reports. I’ll try to do that by this time next week, and identify any patterns I see in them. In the meantime, an intriguing story by the Daily NK elucidates how well-targeted sanctions can drive disloyalties and fissures...

Yesterday’s indictments of the Dandong Hongxiang defendants, who are charged with willfully violating North Korea sanctions by laundering money for sanctioned Korea Kwangsong Banking Corporation, might have been good enough for 2009. They broke the illusion that China’s well-connected bag-men and bag-women were immune from sanctions. To borrow John Park and Jim Walsh’s expression, they meant that we’d finally begun to go after North Korea, Inc. Unfortunately, this isn’t 2009. We’re now in a desperate race to disarm Kim Jong-un, one...