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Sanctions Targeting North Korea

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On September 21, 2017, President Trump issued an Executive Order (“Order”) imposing additional sanctions on North Korea.  The Order is aimed at curbing North Korea’s ability to fund its nuclear and ballistic missile programs by giving the Secretary of the Treasury additional tools to target non-US persons engaging in trade with North Korea and non-US financial institutions supporting such trade.

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.

On 5 August 2017, the United Nations Security Council adopted Resolution 2371/2017 concerning the Democratic People’s Republic of Korea (the “DPRK”). In summary, the measures: prohibit the export of coal, iron ore, lead, lead ore and seafood from the DPRK; restrict any increase of the number of work authorisations for DPRK citizens in Member States without approval from the United Nations Security Council Committee; prevent the opening of new joint ventures or expansion of existing…