1. DPRK Sanctions Overview of current situation, how we got here
Advisories
Recommended steps
Blue sky scenario

2. What Can You Currently Do with DPRK as a US person, or through the US?

3. Nothing

5. What are the current sanctions?
6 U.S. Executive Orders
177 designations in DPRK
67 designations in Russia under DPRK sanctions
22 designations in Russia under DPRK sanctions
10 UNSC Resolutions
155 designations
Sectoral sanctions

6. UN Prohibitions Coal Textiles Seafood & fishing rights
Iron and iron ore
Lead and lead ore
Copper
Nickel
Zinc
Gold
Silver
Titanium ore
Rare earth metals
Vanadium ore
Statues and monuments
Conventional arms
Food and agricultural products
Machinery
Electrical equipment
Earth and stone
Laborers - to be repatriated by Dec 2019
Wood
Vessels

7. Oil / Petroleum - 2 million barrels, down from 4 million annually
UN Restrictions
Oil / Petroleum - 2 million barrels, down from 4 million annually

8. U.S. Blocking Restrictions - EO 13810
the assets of any “North Korean person,” including a North Korean person that has engaged in commercial activity that generates revenue for the Government of North Korea or the Workers' Party of Korea
to operate in the construction, energy, financial services, fishing, information technology, manufacturing, medical, mining, textiles, or transportation industries in North Korea
to have engaged in at least one significant importation from or exportation to North Korea of any goods, services, or technology

9. U.S. Blocking Restrictions - EO 13810
to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked owned by a designated person
to have knowingly conducted or facilitated any significant transaction on behalf of a North Korea-related sanctioned individual or entity, or in connection with trade with North Korea.

10. Advisories - Red Flags
July 2018: Risks for Businesses with Supply Chain Links to North Korea
February 2018: Sanctions Risks Related to North Korea’s Shipping Practices
November 2017: North Korea’s Use of the International Financial System

11. Advisories - Red Flags Brand new customer with immediate high turnover
Mislabeled Good/Services/Technology
Raw Materials or Goods Provided with Artificially Low Prices
Falsifying Cargo and Vessel Documents
Incomplete L/Cs that are missing:
Bills of lading, certificates of origin, invoices, packing lists, proof of insurance, and lists of ports of call

12. Best Practices
North East China and Russia MUST be viewed as a high risk zone
China - Liaoning Province
Dandong
Dalian
Shenyang
Russia - Primorsky Krai - (Province)
Vladivostok
Nakhodka
Manual review of all transactions from these areas
High risk rating for any banks located in these areas

13. Best Practices
Within these high risk areas, once a transaction is flagged, focus on goods:
Imports:
Oil
Dual use or defense technology
Electronics
Exports:
Coal
Textiles
Minerals and metals

14. Blue Sky Scenario North Korea allows in IAEA inspectors
Limited US sanctions relief - related to nuclear sanctions
Continued US sanctions in other areas (human rights, defense procurement)
Limited to medium UN sanctions roll back. Likely in oil imports and coal exports
IAEA verifies that nuclear program has been shuttered
Additional US sanctions relief - likely on Government of North Korea and some banks
Significant UN sanctions relief
Limited new US sanctions
US - DPRK bilateral agreement ending war, agreement on ballistic missiles.
Trump - Kim summit to seal agreement
Significant, but not total US sanctions relief
Snap back agreement

15. Blue Sky Scenario Remaining ProblemsNo
Rule of law
Financial transparency
Business infrastructure
Professional services
Logistics infrastructure
Financial or legal standards
FATF compliance
Yes
Total corruption
Government dominated economy
Remaining sanctions
Decade + of flouting international financial rules and regulations
Political uncertainty

16. Questions