This document outlines sanctions imposed by the U.S. Department of the Treasury’s office of Foreign Assets Control (OFAC) on several individuals and entities connected to North Korea‘s illicit activities. Here’s a breakdown of the key details:
Individuals Designated and Reasons for Designation:
Kim Se Un: designated for having provided, or attempted to provide, financial, material, technological, or other support for, or goods or services in support of, Sobaeksu.Sobaeksu’s property and interests are blocked under executive Order (E.O.) 13382. The State Department has offered a reward of up to $3 million for information leading to Kim Se Un’s arrest and/or conviction.
Jo Kyong Hun: Designated as a North Korea-based Sobaeksu IT team leader who worked with Kim Se Un on cryptocurrency and financial issues for IT projects. He is designated under E.O. 13382 for providing or attempting to provide support to Sobaeksu.
Myong Chol Min: Designated as a North Korea-based trade representative who facilitated business deals and sanctions evasion for revenue generation for North Korea. He also attempted to import tobacco and other products into North Korea. He is designated under E.O. 13810 for engaging in commercial activity that generates revenue for the North Korean government or the Workers’ Party of Korea. The State Department has also offered a reward of up to $3 million for information leading to his arrest and/or conviction.
Key Executive Orders Mentioned:
E.O. 13382: This order targets proliferators of weapons of mass destruction and their supporters. E.O. 13810: This order targets persons engaged in certain activities that violate or circumvent sanctions against North Korea.
Sanctions Implications:
Asset Blocking: All property and interests in property of the designated individuals that are in the United States or controlled by U.S. persons are blocked.
Entity Blocking: Any entities owned 50% or more by one or more blocked persons are also blocked.
Prohibited Transactions: U.S. persons are generally prohibited from engaging in any transactions involving the property or interests in property of blocked persons, unless authorized by OFAC. This includes providing funds, goods, or services to or for the benefit of blocked persons, or receiving them from blocked persons.
Penalties: Violations of U.S. sanctions can lead to civil or criminal penalties for both U.S. and foreign persons. OFAC can impose civil penalties on a strict liability basis.
Enforcement: The document references OFAC’s Economic Sanctions Enforcement Guidelines for more information on enforcement. Risk Exposure: Financial institutions and others risk sanctions exposure for engaging in certain transactions or activities with designated or blocked persons.process for Removal from OFAC Lists:
The document also provides information on the process for seeking removal from OFAC lists, emphasizing that the goal of sanctions is to bring about positive change in behavior.
In essence, this document announces the U.S. government’s action to sanction individuals involved in North Korea’s revenue-generating activities, particularly those linked to illicit IT projects and sanctions evasion, and highlights the legal and financial consequences for those who engage with these sanctioned individuals.
