In a continuing effort to pressure and isolate North Korea by targeting entities and individuals in third countries, on Tuesday, August 22, 2017, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) and US Justice Department (“DOJ”) announced sanctions and a civil forfeiture action, respectively, targeting Chinese and Russian entities accused of directly or indirectly assisting or supporting North Korea’s nuclear and ballistic missile programs. China is North Korea’s primary trading partner and these actions appear to be an effort, in part, to ramp up pressure on China to assist in curtailing its neighbor’s nuclear ambitions.
Ending a five-year investigation, ZTE Corp. (“ZTE”), the second-largest producer of telecommunications equipment in China, entered into a plea agreement with the US Department of Justice (“DOJ”) and settlement agreements with the US Department of Commerce’s Bureau of Industry (“BIS”) and the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”), for violations of US sanctions against Iran and US export controls, making false statements to the US government, and obstruction of justice (complete plea/settlement agreements are available at the following links: DOJ, BIS and OFAC). If the criminal plea with the DOJ is approved by a federal judge, the combined $1.19 billion in penalties would be the largest fine and forfeiture ever levied by the US government in an export control case.