On 19 December 2022, South Korea’s Ministry of Foreign Affairs (“MOFA”) announced new unilateral sanctions against Russian entities and individuals apparently involved in illegal military cooperation with North Korea in violation of UN Security Council resolutions.  The sanctions target the illegal procurement of funds and materials for North Korea’s weapons programs.

MOFA stated that the designations include Russian companies such as LLC Verus for its involvement in arms brokering between Russia and North Korea, Parsek LLC for its provision of key missile materials and technology to North Korea, and Ardis-Bearings LLC for supporting the development of North Korea’s weapons programs.  A number of Russian individuals and associated entities were also sanctioned for procuring materials for North Korea. 

In particular, MOFA stated that several Russian banks have been designated for engaging in illicit financial transactions with North Korea, including MRB Bank, TSMR Bank, Russian Financial Corporation, Stroytreyd LLC, and Timer Bank.

Many of these Russian parties are already sanctioned by other jurisdictions, such as the United States.  

The sanctions prohibit any financial or foreign exchange transactions with the designated targets without prior approval from MOFA under the Act on Prohibition against the Financing of Terrorism and Proliferation of Weapons of Mass Destruction (“PFOPIA”) as well as the Foreign Exchange Transactions Act (“FETA”).  Violations can result in imprisonment of up to 10 years or a fine of up to KRW 100 million under the PFOPIA and imprisonment of up to three years or a fine of up to KRW 300 million under the FETA.

The new sanctions serve as a strong warning to those dealing with the designated Russian entities and financial institutions that they could face significant legal risks.  By targeting Russia’s illicit activities and coordinating with international partners, South Korea is demonstrating its firm commitment to implementing UN Security Council resolutions and increasing pressure on Russia and North Korea to curb the financing and support of North Korea’s weapons programs.