ARTICLE
24 August 2018

OFAC Adds Foreign Entities And Individual To Sanctions List For Illicit Shipping Activity

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Cadwalader, Wickersham & Taft LLP

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The U.S. Treasury ("Treasury") Office of Foreign Assets Control ("OFAC") designated one individual and three entities for their roles in facilitating illicit shipments ...
United States International Law

The U.S. Treasury ("Treasury") Office of Foreign Assets Control ("OFAC") designated one individual and three entities for their roles in facilitating illicit shipments on behalf of North Korea, pursuant to Executive Order 13810.

OFAC stated that it took this action in accordance with the "United States' ongoing commitment to prevent[ing] financial flows to the [North Korean Regime's] unlawful WMD programs and activities, in accordance with the decisions of the UN Security Council." OFAC reported that it designated a Chinese-based company and its Singapore-based affiliate for forging shipping documents for the export of illicit shipments of alcohol, tobacco and cigarette-related products to North Korea. OFAC also determined that the designated Russia-based company and its Director General were providing port services to North Korea-flagged vessels. OFAC stated that the Russia-based company continued to offer bunkering services to "DPRK-flagged vessels," despite its awareness of oil-related sanctions against North Korea.

Treasury reminded the shipping industry, which includes "flag states, ship owners and operators, crew members and captains, insurance companies, brokers, oil companies, ports, classification service providers, and others," of the risks associated with North Korea's shipping practices. In an Advisory issued in February 2018, Treasury outlined (i) deceptive shipping practices used by North Korea to avoid sanctions, (ii) ways for the shipping industry to mitigate risks posed by North Korea's deceptive practices and (iii) penalties for individuals and entities that violate U.S. and UN sanctions against the North Korean Regime.

As a result of OFAC's action, U.S. persons are barred from dealing with any of the designees, and all properties and interests in property of the designees that are in the possession or control of U.S. persons or within the United States must be blocked.

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