July 31, 2019 | Policy Brief

Treasury Sanctions North Korean for Sanctions Evasion

July 31, 2019 | Policy Brief

Treasury Sanctions North Korean for Sanctions Evasion

The Treasury Department on Monday sanctioned a North Korean trading company official for helping Pyongyang evade U.S. and UN sanctions through illicit activity in Vietnam. The designation, which arrived in the brief interval between two North Korean missile tests in less than a week, suggests that Washington understands the importance of investigating and disrupting North Korea’s extensive overseas illicit networks.

Treasury’s latest target is Kim Su Il, who works for a Vietnam-based trading company on behalf of North Korea’s Munitions Industry Department, which the U.S. and UN have both sanctioned. According to Treasury, Kim helped export UN-sanctioned goods such as anthracite coal, titanium ore concentrate, and other raw materials from North Korea to Vietnam. Both anthracite coal and titanium ore are among the top exports that fund the regime’s illicit activities. Treasury also found that Kim Su Il helped charter ships and export Vietnamese products to North Korea, as well as to China and other undisclosed countries.

Kim Su Il’s designation is a reminder that North Korea’s overseas networks continue to thrive despite sanctions. In January, The Wall Street Journal reported that up to six Chinese-owned vessels transported North Korean coal between North Korea and Vietnam throughout 2018. In March 2018, the UN Panel of Experts also found that North Korean coal shipments to Vietnam go as far back as January 2017 – eight months before the UN Security Council’s comprehensive coal ban on North Korea went into effect. This persistent trade affirms Assistant Secretary of the Treasury Marshall Billingslea’s assessment in 2017 that coal “has been the center of North Korea’s revenue generation” for many years.

In March 2019, the same UN Panel of Experts exposed North Korea’s numerous overseas illicit money-making schemes, which employ networks of front companies, North Korean government workers, and local banks. For example, in Malaysia, North Korea’s intelligence agency, the Reconnaissance General Bureau, operated two companies that provided revenue to Pyongyang: the Malaysia-Korea Partners Group and Global Communications.

The UN Panel also found that foreign governments were applying “insufficient scrutiny” on the activities of North Korea’s overseas banking and government representatives, thereby enabling these company networks to thrive. The lax monitoring has ultimately allowed Pyongyang’s representatives to conduct financial transactions across numerous borders. Chinese banks in particular have been key enablers of North Korea’s actions.

Treasury provided robust evidence of this lax oversight last month when it sanctioned the Russian Financial Society (RFS) for helping North Korea evade sanctions. This designation revealed how a U.S.-sanctioned North Korean banking representative in Moscow exploited local financial service providers, specifically RFS, to conduct business for sanctioned North Korean companies. The incident showed that designating only the North Korean nationals working abroad is not enough. Rather, Washington also should target the banks and financial institutions that allow North Korean government officials based overseas to thrive.

Treasury’s next steps therefore should focus on investigating Kim Su Il’s local network of companies, individuals, and banks. Closing these gaps in enforcement is an indispensable step for maximizing the impact of U.S. sanctions on North Korea.

Mathew Ha is a research associate focused on North Korea at the Foundation for the Defense of Democracies (FDD), where he also contributes to the FDD Center on Economic and Financial Power (CEFP). Follow Mathew on Twitter @MatJunsuk. Follow FDD on Twitter @FDD and @FDD_CEFP. FDD is a Washington, DC-based, nonpartisan research institute focusing on national security and foreign policy.


China International Organizations North Korea Sanctions and Illicit Finance