New North Korea Sanctions Will Produce Mixed Results 

The Biden administration issued three sets of sanctions last week on individuals and entities providing military or financial support to North Korea. However, the sanctions will probably produce mixed results, as some of them are symbolic or target only the North Korean parts of a sanctions evasion network, while others are effective since they probably focus on all the parties in the transaction.  

Last week, the U.S. Department of the Treasury sanctioned a total of nine individuals and seven entities, including North Korean banks, key banking representatives, and Russian companies that facilitated the shipment of oil and gas to North Korea from 2022 to at least April 2024. The targets also include North Korean military officials supporting Pyongyang’s weapons programs and Moscow’s war against Ukraine. 

However, the sanctions on two North Korean banks are largely symbolic, since U.S. and UN sanctions on North Korea have forced Pyongyang to rely less on banks and more on front companies and representatives to access the international financial system. 

By contrast, Treasury’s sanctions on four Russian companies as well as a North Korean-based company involved in shipping oil and gas are effective penalties because they probably cover all the parties in the transactions. 

Sanctioned North Korean officials include Kim Yong Bok, a senior general of the Korean People’s Army; Ro Kwang Chol, the national defense minister; Ri Chang Ho, head of the Reconnaissance General Bureau (RGB); and Ju Chang Il, the director of the North Korean organization responsible for censorship.  

A Treasury press release explained that Kim and Ri are accompanying North Korean troops in Ukraine. Treasury also said that Ri “has conducted revenue generating activities and securing funds in support of the DPRK’s WMD activities.” Ri’s presence in Ukraine is particularly troublesome since Treasury previously described RGB in 2023 as North Korea’s “primary intelligence bureau and main entity responsible for the country’s malicious cyber activities.” Ri could be using his time in Ukraine to bolster North Korea’s intelligence on military tactics. 

Sanctioning senior North Korean officials is useful if it publicly highlights that the individuals, like those sanctioned by Treasury, are involved in prohibited activities. 

Also last Monday, the State Department sanctioned one entity and two individuals procuring items for Pyongyang’s prohibited missile programs. However, the State Department failed to sanction the key Chinese entities, individuals, and banks that have facilitated this procurement. If sanctions do not include them, they will not be effective in addressing North Korea’s problematic activities. 

Last Tuesday, the Treasury Department sanctioned two UAE-based Chinese nationals and a UAE-based front company that worked with Sim Hyon Sop, a North Korean national based in China, from early 2022 to approximately September 2023. The network exchanged cryptocurrency for fiat cash worth several millions of dollars, which was used to purchase products and services for North Korea or its proxies. Sanctions against this money laundering network are constructive because they could constrain its operations. However, the sanctions raise questions about why Washington waited more than a year to impose them.  

These questions are particularly salient because Treasury previously sanctioned Sim in April 2023 for coordinating millions of dollars in financial transfers for North Korea in his capacity as a representative of Korea Kwangson Banking Corp. Sim is also wanted by the FBI for various charges, including conspiracy to commit bank fraud. The FBI is offering a reward of up to $5 million for information leading to his arrest and conviction. 

Sanctions should be a crucial part of the incoming Trump administration’s North Korea policy and will help efforts to broker a Russia-Ukraine peace. The new team should focus on making North Korean leader Kim Jong Un face consequences for his malign conduct and shy away from symbolic and partial actions.  

Anthony Ruggiero is an adjunct senior fellow at the Foundation for Defense of Democracies (FDD). He previously served in the U.S. government for more than 19 years, including as director for North Korea (2018-2019) and senior director for counterproliferation and biodefense on the National Security Council (2019-2021). For more analysis from Anthony and FDD, please subscribe HERE. Follow Anthony on X @NatSecAnthony. Follow FDD on X @FDD. FDD is a Washington, DC-based, nonpartisan research institute focused on national security and foreign policy.