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Financial Services Law Insights and Observations

OFAC Imposes Additional North Korean Sanctions; Senate Banking Committee Hearing Discusses Multi-Department Efforts

Financial Crimes Sanctions OFAC Department of Treasury Senate Banking Committee Department of State North Korea

Financial Crimes

On September 26, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced it was imposing sanctions on an additional eight North Korean banks and 26 individuals connected to North Korean financial networks across the globe. The individuals sanctioned are North Korean nationals who represent North Korean banks operating in China, Russia, Libya, and the UAE, and have been designated “in response to North Korea’s ongoing development of weapons of mass destruction and continued violations of United Nations Security Council Resolutions.” OFAC’s action complements the United Nations Security Council’s resolution UNSCR 2375, adopted September 11, 2017. As a result, property or interests in property of the designated persons within U.S. jurisdictions are blocked.

These actions closely follow President Trump’s recent issuance of sanctions targeting individuals, companies, and financial institutions that finance or facilitate trade with North Korea. (See previous InfoBytes coverage here.)

Additionally, the Senate Committee on Banking, Housing, and Urban Affairs (Committee) held an open session hearing on September 28 entitled “Evaluating Sanction Enforcement and Policy Options on North Korea: Administration Perspectives.” Committee Chairman Mike Crapo (R-Idaho) opened the hearing to stress that “[m]any Members of Congress, including on this committee, have a keen interest in knowing more about how and when enforcement of these new measures will occur, wondering if last week’s executive order and earlier UN sanctions will be sufficient to achieve U.S. policy goals.” Sen. Crapo also mentioned the Committee’s legislative efforts to “maximize pressure against North Korea.”

The September 28 hearing—a video of which can be accessed here—included testimony from the following witnesses concerning North Korea’s nuclear and ballistic missile program and the need to curtail the country’s access to revenue, trade, and financial systems.

  • The Honorable Sigal Madelker, Under Secretary for Terrorism and Financial Crimes, U.S. Department of the Treasury (testimony)
  • Ms. Susan A. Thornton, Acting Assistant Secretary, Bureau of East Asian and Pacific Affairs, U.S. Department of State (testimony)