On 6th June, the Institute for Science and International Security published a report concerned with the annual report of the UN Panel of Experts on North Korea, covering the year to February 2019.  The UN report mentions over a 100 new, continuing, or unresolved proven or alleged violations involving 56 countries, territories, and entities.  31 of the 56 states listed in that report were allegedly responsible for multiple sanctions violations.  The 56 countries involved in alleged violations during the reporting period, listed in alphabetical order, were:

Algeria*, Belize, Botswana, BVI, Cambodia, China, Comoros, DRC, Côte d’Ivoire, El Salvador, Equatorial Guinea, Eritrea, France, Georgia, Ghana, Guinea, Honduras, Hong Kong, India, Indonesia, Iran, Laos, Lebanon, Libya, Madagascar, Malaysia, Malta, Mexico, Mozambique, Myanmar, Namibia, New Zealand*, Nicaragua, Nigeria, Panama, Philippines, Poland, Russia, Serbia, Seychelles, Sierra Leone, Singapore*, South Africa, Sudan, Syria, Taiwan, Tanzania, Thailand, Togo, Tunisia, Uganda, UAE, Vietnam, Yemen (Houthi faction), and Zambia.

*Indicates that a country took remediating, prosecutorial action during the reporting period to rectify or penalise one or several alleged sanctions violations.

The report divides violations into 5 groups: military-related; business and financing-related; DPRK Procurement-related (goods going to North Korea); Import-related (goods coming from North Korea); and shipping-related violations.

15 states were mentioned in the 2019 report for alleged involvement in military-related sanctions violations.  The remaining 41 countries were included in the Panel’s report for alleged non-military related sanctions violations, and the majority of all business and financial-related incidents listed in the report seemed to involve 5 key states or territories – China, Hong Kong, Malaysia, Russia, and UAE.  Several alleged business and financial-related violations occurred as joint ventures with DPRK actors, and several alleged business and financial-related violations occurred as violations of restrictions on the provision of financial services as well as the maintenance of representative offices of DPRK banks.  The Institute chose to separately discuss alleged shipping-related sanctions violations, such as the provision of a vessel, flag, insurance, or registry, and with at least 16 countries or territories failing to prevent, prohibit, or act upon alleged procurement violations, where sanctioned goods and minerals, such as coal, oil, and petroleum products, were imported by the DPRK.  14 countries were mentioned in the Panel report for failing to uphold sanctions on the DPRK’s vessel-related and shipping activities – including failure to inspect cargo destined to, originating from, or brokered by the DPRK; failure to prohibit the activities of nationals or entities incorporated in their territory or subject to their jurisdiction, or vessels flying their flag, from facilitating or engaging in ship-to-ship transfers to or from DPRK-flagged vessels; and failure to de-register vessels involved in violating DPRK sanctions, among others.



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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