EXPLORING THE PERSISTENT ROLE OF DIPLOMATIC MISSIONS IN NORTH KOREA’S WMD PROLIFERATION AND ARMS TRAFFICKING NETWORKS

A paper from Daniel Salisbury dated 5 July is now freely available online and says that North Korea frequently uses diplomatic missions, diplomats and intelligence officers in its WMD proliferation and arms trafficking networks. The paper identifies a number of trends surrounding the use of North Korean missions – including the types and locations of missions featuring in specific types of proliferation and arms dealing activities, the prominence of larger missions and use of third country and regional hubs.  It argues that the persistence of these assets in the DPRK’s networks is largely a result of convenience and diplomatic immunity.  The paper concludes by recommending further action to counter these assets while arguing that the phenomenon will continue to be a challenging feature of North Korea’s proliferation and arms trading activities.

https://www.tandfonline.com/doi/full/10.1080/14799855.2021.1942848

GLOBAL FEDERATION OF INSURANCE ASSOCIATIONS (GFIA) POSITION PAPERS ON AML/CFT

The GFIA has a number of useful and/or interesting papers on its website, including the following –

Position paper on the application of AML to general insurance

This Paper from 6 May concludes that there is no evidence to justify extending AML/CFT rules to general insurance.

https://gfiainsurance.org/mediaitem/d3e45eff-af3c-4d76-9b98-251007fde95b/GFIA%20position%20paper%20on%20AML%20and%20general%20insurance.pdf

Comments on the FATF public consultation on the draft Amendments to Recommendation 24

This paper from 24 August contains the GFIA response to possible changes to the Recommendation on transparency and beneficial ownership.

https://gfiainsurance.org/mediaitem/7dcf28f5-6393-4e3b-9ac7-034df148ccf5/GFIA%20response%20to%20FATF%20consultation%20on%20revisions%20to%20Recommendation%2024.pdf

Response to IAIS consultation on draft revised Application Paper on Combatting Money Laundering and Terrorist Financing

This paper from 16 July contains the GFIA response to the draft from the International Association of Insurance Supervisors (IAIS) of 17 May on how money laundering and terrorist financing can occur within the insurance sector, and on measures to mitigate the associated risks. 

https://gfiainsurance.org/mediaitem/efb42c30-011f-4c69-93ee-d1b134f2074b/GFIA%20response%20to%20IAIS%20consultation%20on%20draft%20application%20paper%20on%20CML%20and%20TF.pdf

https://www.iaisweb.org/page/consultations/closed-consultations/2021/draft-revised-application-paper-on-combating-money-laundering-and-terrorist-financing

EU RECOMMENDATION ON DUAL-USE CONTROLS INTERNAL COMPLIANCE PROGRAMMES (ICP)

This non-binding Recommendation of 15 September provides a framework to help research organisations and researchers, research managers and compliance staff to identify, manage and mitigate risks associated with dual-use export controls and to facilitate compliance with the relevant EU and national laws and regulations. It also provides a framework to support Member States competent authorities in developing specific outreach programmes, as well as in their assessment of risks related to research activities, in the exercise of their responsibility for deciding on export authorisations for dual-use items.  It includes a section of helpful FAQ.

ILLICIT WEAPONS IN AFGHANISTAN: TALIBAN SEIZURES OF US-EQUIPMENT ARE ONLY A FRACTION OF THE STORY

Conflict Arms Research has produced this report saying that, between February 2019 and July 2021, CAR investigators worked in Afghanistan to document illicit weapons in the country.  It says that very little attention has been paid to the group’s long-standing ability to exploit weaknesses in US and Afghan government controls over weapon supplies. Taliban access to weapons and ammunition intended for Afghan security forces is not new, but it has expanded significantly over time and was less reliant on external sources than might have been supposed.  It warns that recent events in Afghanistan highlight the need to address persistent challenges and weaknesses in the US supply of weapons, ammunition, and military equipment to other government-backed forces in other countries affected by armed conflict and terrorism.  This report is the first in a series that will draw out key findings from CAR’s Afghanistan data set. It explores the long-standing capacity of the Taliban and other armed actors in Afghanistan to access weapons that had been supplied by the US and NATO to Afghan forces, and considers the systemic challenges that have enabled weapon diversion from national custody in the past. It focuses on small arms and light weapons and does not delve into issues around the seizure of aircraft or other equipment.

https://storymaps.arcgis.com/stories/773ba742c1d1402582bb0ccc38414b34

Trade and customs in the UK beyond Brexit

On 23 September, Clifford Chance published a briefing saying that, for the first time in 48 years, importers and exporters must grapple with a UK trade and customs administration entirely independent from the EU, including new domestic regulations, international trade agreements and, in some cases, government agencies.  The briefing considers the legal framework and the international one, trade defence investigations, customs duties, trade barriers, export controls, financial and other sanctions measures and trade embargoes; plus what it describes as “current trends”.

https://www.cliffordchance.com/content/dam/cliffordchance/briefings/2021/09/trade-and-customs-in-the-uk-beyond-brexit.pdf

North Korean Sanctions Evasion Techniques

The RAND Corporation has published this report saying that the UN imposed increasingly restrictive sanctions on North Korea after each of the six nuclear weapons tests that it conducted between 2009 and 2016.  However, enforcement of those sanctions has been mixed.  It describes the multilateral arms control mechanisms available and sanctions regimes imposed on North Korea to contain its proliferation activities and bring that country back into compliance with international law.  It details the various entities involved in North Korean sanctions evasion activities and proceeds to use case studies to illustrate North Korea’s principal sanctions evasion techniques in 4 general areas of sanctions evasion activity: hard-currency generation, restricted and dual-use technology acquisition, covert transport, and covert finance. It says that 4 types of entities are involved in North Korea’s sanctions evasion: North Korean government officials accredited to North Korea’s embassies, North Korean overseas workers, front and shell companies, and trusted third-party intermediaries.  North Korea is said to “active” in 38 African countries, and has aided or fuelled ballistic missile programmes in the Middle East.

https://www.rand.org/content/dam/rand/pubs/research_reports/RRA1500/RRA1537-1/RAND_RRA1537-1.pdf

Preventing North Korean Proliferation Activities

On 23 September, the RAND Corporation published an article saying that the UN has raised concerns about the widespread presence of North Korean nationals in Africa and their involvement in prohibited activities. For example, it says, North Korea engages in proliferation related activities in 38 of 54 African countries, and North Korea proliferates weapons to 13 African countries. RAND’s National Security Research Division assisted the US Department of State in producing guides, other supporting materials that explain why North Korean proliferation activities matter, and steps that can be taken to mitigate those activities. The project’s first 2 reports are available for download now. A third report on strategic trade controls is forthcoming.

North Korea sanctions: Countering DPRK Proliferation Activities

https://www.rand.org/pubs/tools/TL332.html

How does North Korea Evade Sanctions?

https://www.rand.org/pubs/research_reports/RRA1537-1.html

UK Government report says that North Korean diplomats engaging in illicit financing activities

On 25 September, Yonhap News reported that the recent UK National Risk Assessment of proliferation financing says that North Korean Embassies and diplomatic personnel are engaging in illicit financing activities to fund the country’s nuclear and other destructive weapons activities.  It is also said that the North Korean Embassy in London “may pose an inherent” risk, as not all banks in the country may be attuned to UN sanctions that restrict such activities.

https://en.yna.co.kr/view/AEN20210925002600325