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Sanctions Targeting North Korea

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On July 27, 2017, the US Senate approved in a 98-2 vote H.R. 3364, the “Countering America’s Adversaries Through Sanctions Act” (“H.R. 3364”).  We previously summarized H.R. 3364 in our blog posts here and here.  H.R. 3364 now goes to the White House where the President will have 10 days to (1) sign the bill, (2) veto the bill, or (3) permit the bill to become law without his signature.  The 10-day clock will start when the US Congress delivers H.R. 3364 to the President, which may happen in a few days. 

Last month, the US Senate passed significant Russia sanctions legislation as an amendment to an Iran sanctions bill targeting Iran’s ballistic missile program. The Russia sanctions provisions sought to limit the President’s ability to relax existing US sanctions targeting Russia while imposing additional restrictions impacting various sectors of the Russian economy.  The key provisions of the Senate bill are summarized in our earlier blog post

The European Council (the “Council”) has adopted conclusions relating to the Democratic People’s Republic of Korea (the “DPRK”). Therein, the Council expresses concern about the regime’s activities to raise hard currency to fund its nuclear and ballistic missile programmes. While the Council notes that EU sanctions against the DPRK are amongst the most restrictive, it states that it will consider further appropriate responses in consultation with key partners and in line with UN Security Council…

On June 29, 2017, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued for public inspection a notice of proposed rulemaking (the “Proposed Rule”) that would restrict a Chinese commercial bank’s access to the US financial system based on a finding that the bank was involved in money laundering activities involving North Korea. This action coincided with designations by the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) of one entity and two individuals with alleged ties to North Korea.