ARTICLE
24 February 2020

Treasury Sanctions Entities For Facilitating The Exportation Of Workers From North Korea

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Squire Patton Boggs LLP

Contributor

Squire Patton Boggs LLP
The US Department of the Treasury's Office of Foreign Assets Control (OFAC) announced on January 14, 2020, two North Korea-related designations focusing...
Worldwide International Law

The US Department of the Treasury's Office of Foreign Assets Control (OFAC) announced on January 14, 2020, two North Korea-related designations focusing on the government of North Korea's continued supply of illicit labor to overseas markets. The action targets a North Korean trading corporation, Namgang Trading Corporation, and a China-based North Korean lodging facility, Beijing Sukbakso, that facilitate North Korea's practice of sending laborers abroad. North Korea's continued export of North Koreans as illicit laborers is part of an ongoing attempt to undermine and evade UN Security Council Resolutions (UNSCR) 2375 and 2397; UN member states were obligated to expel all North Korean laborers by December 22, 2019, in a manner consistent with UNSCR 2397

Under these sanctions, all property and interest in property of these two entities that are in the US or in the possession or control of US persons must be blocked and reported to OFAC. OFAC's regulations generally prohibit all dealings by US persons or within the US (including transactions transiting the US) that involve any property or interests in property of blocked or designated persons. Additionally, any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the entities designated under these sanctions could be subject to US secondary sanctions.

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