Sanctions Targeting North Korea


The US Departments of State, Treasury, and Homeland Security warned companies in a new advisory that deceptive practices by North Korea to evade US, UN, and other sanctions could put them at risk of prohibited or sanctionable dealings with the North Korean regime.  The advisory published on July 24, 2018 follows February 2018 guidance from the US Treasury Department’s Office of Foreign Assets Control regarding certain deceptive shipping practices of North Korea to avoid US sanctions (see our prior blog post here).  The new advisory encourages companies to undertake enhanced due diligence within their supply chains to avoid prohibited or sanctionable: (i) sourcing of goods, services, or technology from North Korea and (ii) use of the labor of North Korean citizens or nationals, which is presumed to be forced labor, regardless of where such labor occurs.

On 25 April 2018, the Swiss Federal Council announced that it once again tightened sanctions against the Democratic People’s Republic of Korea (North Korea) thereby implementing UN Security Council Resolution 2397 (2017). The new provisions entered into force at 6 pm on 25 April. The announcement said: Following the North Korean ballistic missile tests of 28 November 2017, which violated all previous Security Council resolutions, the UN Security Council adopted Resolution 2397 (2017) on 22 December 2017,…

On March 1, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced the amendment and reissuance in their entirety of the North Korea Sanctions Regulations, 31 C.F.R. Part 510 (“NKSR”). A public inspection copy of the Final Rule can be found here. These changes to the NKSR will take effect on March 5, 2018 upon publication in the Federal Register. OFAC also published 13 new FAQs, which can be found here.

As part of its continuing efforts to isolate North Korea from the world economy, on February 23, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced new sanctions measures targeting North Korea’s shipping industry and issued an advisory document entitled “North Korea Sanctions Advisory,” which highlights sanctions risks in the global shipping industry.