The Sentry has published a report saying that, in 2018, 2 North Korean businessmen formed a construction services company, Congo Aconde, in the DRC and engaged in activities that appear to violate sanctions adopted by the EU, the UN, and the US. Its activities included erecting statues in a remote provincial capital, a type of construction explicitly forbidden by UN sanctions adopted in 2016. The investigation raises significant questions about the enforcement of sanctions on North Korea and demonstrates apparent failures at multiple levels of the DRC government and by several banks to conduct proper due diligence on Congo Aconde, including an account at the DRC affiliate of Afriland First Bank, an institution headquartered in Cameroon.  It says that Congo Aconde serves as a clarion call for banks, governments, and multilateral institutions regarding sanctions risks in the DRC. Weak internal controls and oversight mechanisms in the DRC make it a fertile ground for those seeking to evade sanctions. These frailties put the DRC’s banking sector and the broader economy in significant danger.

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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