On July 6, 2016, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that it had added 16 new North Korean parties, including 11 individuals and 5 entities, to the Specially Designated Nationals and Blocked Persons List (“SDN List”).  The Treasury Department has issued a press release related to the designations.  The new SDNs include North Korea leader Kim Jong Un, other top officials of the North Korean regime, and certain North Korean government entities.  The parties were designated as Specially Designated Nationals (“SDNs”) pursuant to Executive Orders 13722 and 13687 for their ties to human rights abuses in North Korea. 

US Persons are generally prohibited from engaging in any dealings, directly or indirectly, with SDNs or with any entity 50% or more owned by one or more SDNs. In addition, any property or interest in property of SDNs that come within the possession or control of a US person or are located in the United States must be “blocked” (i.e., frozen).

In addition to Kim Jong Un, some examples of other designated parties and the reasons for their designations (according to the Treasury Department press release) include:

  • The Ministry of State Security, which engages in torture and inhumane treatment of detainees during interrogation and in detention centers.
  • The Ministry of State Security Prisons Bureau, which is responsible for the management and control of political prisoners and their confinement facilities throughout North Korea, and which operates North Korean political prison camps where serious human rights abuses occur.
  • The Ministry of People’s Security, which operates a network of police stations and interrogation detention centers, including labor camps, throughout North Korea, where suspects are systematically degraded, intimidated, and tortured during interrogations.
  • The Ministry of People’s Security Correctional Bureau, which supervises labor camps and other detention facilities where human rights abuses occur.
  • The Organization and Guidance Department, a body of the North Korean regime that is instrumental in implementing North Korea’s censorship policies.
  • Certain top officials of the Government of North Korea or the Workers’ Party of Korea, including officials of certain of the above entities.

The new designations by OFAC were made in conjunction with the US State Department’s issuance of a “Report on Human Rights Abuses and Censorship in North Korea,” which identifies North Korean officials and entities responsible for or associated with serious human rights abuses or censorship.  The SDN List additions and release of the State Department report are the latest steps in recent US Government efforts to enhance sanctions against North Korea consistent with the North Korea Sanctions and Policy Enhancement Act of 2016, which was passed by Congress and signed into law by President Obama in February, as discussed in previous blog posts, including here and here.


Kathryn Anderson is an associate in Baker McKenzie's International Commercial Practice Group in San Francisco. Kathryn's practice focuses on cross-border transactions and international trade regulation, including export controls, trade and investment sanctions, anti-terrorism controls, and customs and import regulations. Her practice also covers anti-corruption rules and international corporate compliance.


Ms. Test advices clients on issues relating to licensing, regulatory interpretations, enforcement actions, internal investigations and compliance audits, as well as the design, implementation and administration of compliance programs. She also advises clients on the extra-territorial application of trade compliance-related regulations in cross-border transactions.