On 12 September, OFSI issued an advisory note, which emphasises threats to the compliance with UK and UN sanctions relating to the Democratic People's Republic of Korea ("DPRK"). Those threats relate to DPRK's IT workers fraudulently gaining employment with UK, US and other overseas companies to raise revenue for the North Korean regime.
The DPRK is subject to the UN, UK and other international sanctions aimed at countering proliferation of weapons of mass destruction and ballistic missiles. Individuals and companies that employ or pay DPRK IT workers can indirectly or directly breach the financial sanctions in place.
A breach of the UK financial sanctions may constitute a civil and/or criminal offence, with heavy financial penalties or imprisonment for up to 7 years.
The OFSI advisory provides details on how DPRK IT workers operate, their methods and practices, and red flags to pay attention to. It should be read together with OFSI Statutory Guidance on DPRK.
DPRK IT workers often use fake identities and pose as non-DPRK nationals in order to secure freelance contacts. These workers often operate from third countries, including places in Africa and Latin America.
DPRK IT workers have skills in many areas, including animation, IT support, graphic design and software development.
The affected UK sectors include:
- Information Technology
- Electronic Money Institutions (EMI)/Money Service Businesses (MSB)
- Professional Services
- Cryptocurrency.
We recommend individuals and entities to remain vigilant and ensure that they have advanced compliance policies and systems in place.
Gherson lawyers can assist with the development of sanctions policies and provide required training for businesses and their employees.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.