On 23rd July, the US Department of State, US Treasury and the Department of Homeland Security issued an Advisory to highlight the sanctions evasion tactics used by North Korea that could expose businesses – including manufacturers, buyers, and service providers – to sanctions compliance risks under US or UN sanctions.  This advisory also assists businesses in complying with the requirements of CAATSA Act in the US.  The Advisory covered –

  • the heightened risk for and potential indicators of goods, services, and technology with a North Korean nexus – including from subcontractors; misidentified goods, service or technology; raw materials or goods provided with artificially low prices; and joint ventures;
  • the heightened risk for and potential indicators of North Korean overseas labour – saying that North Korea exports large numbers of labourers to fulfil a single contract in various industries, including but not limited to apparel, construction, footwear manufacturing, hospitality, IT services, logging, medical, pharmaceuticals, restaurant, seafood processing, textiles, and shipbuilding. It provides a long list of those countries which may be impacted, and it provide potential indicators of the use of North Korean labour;
  • due diligence best practice – saying that businesses should closely examine their entire supply chain(s) for North Korean labourers and goods, services, or technology, and adopt appropriate due diligence best practices;
  • potential penalties and enforcement action that could result from violations; and
  • the activities that could result in you (or your supplier, partner, customer etc) being designated by OFAC


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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