If you are involved in, or interested in, export and trade controls, UN and EU sanctions or the proliferation of WMD you should read/have read this paper, and maybe particularly the last of the 4 studies, which looks at how North Korea used an offshore arrangement through panama to circumvent sanctions.

In the December 2017 a paper from the Middlebury Institute of International Studies at Monterey University, “Countering North Korean Procurement Networks Through Financial Measures: The Role of Southeast Asia”, was made up of 4 studies intended to aid SE Asian governments and financial institutions in their efforts to counter the financing of WMD programmes in North Korea and other states of concern.  The 4 studies (which can be viewed and downloaded separately) are –

  • Countering North Korean Procurement Networks Through Financial Measures: The Role of Southeast Asia – highlights how North Korea has exploited weak financial controls in the region to advance its nuclear and missile programmes. The study reviews UN Security Council and FATF actions to combat such abuse of the international banking system, as well as the role of US sanctions.  Effective implementation of these measures in SE Asia, the study concludes, could contribute significantly to constraining North Korea and other proliferant states.
  • Needed Next Steps to Strengthen Measures to Counter Proliferation Finance – identifies gaps in international measures to combat proliferation finance, and calls on the UN Security Council and FATF to clarify standards for national-level implementation of counter-proliferation-finance rules and to adopt improved enforcement mechanisms.
  • Chinpo Shipping: A Singaporean Financial Agent of North Korea – how North Korea created an offshore de facto bank in Singapore to finance its illegal activities and how Singapore’s courts addressed the first known prosecution for financing proliferation. The case underscores that greater due diligence by banks and regulatory authorities is urgently needed.
  • Due Diligence And The Panama Papers Episode: Lessons For Proliferation Finance – shows how a North Korean bank, denied access to the international banking system, set up an offshore entity to transact its business. The analysis calls for greatly strengthened enforcement efforts by offshore tax havens, closer scrutiny of clients by banks and law firms conducting international business, and greater efforts by governments to block sanctions-violating front companies from accessing their banking systems.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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