On 23 July, an article from Paul Weis about penalties imposed on a global supplier of cigarette products incorporated in the UAE for supplies to North Korea and using false documentation claiming front companies as the nominal purchasers and the ultimate destination as China. This was said to be the first prosecution for violation of the North Korea Sanctions Regulations and the first DoJ criminal resolution with a non-US and non-bank company for selling ordinary products or services to a sanctioned jurisdiction where the only US nexus was use of the US financial system (including use of a non-US branch of a US bank) – previously, such conduct was generally not treated as warranting DoJ criminal enforcement.
