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Sanctions Targeting North Korea

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On April 10, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a rule amending the North Korea Sanctions Regulations (“NKSR”). The NKSR amendments implement certain provisions of the North Korea Sanctions and Policy Enhancement Act of 2016 (“NKSPEA”), as amended by the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), and the National Defense Authorization Act for Fiscal Year 2020 (“2020 NDAA”). Our prior blog post on NKSPEA can be found here…

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,…