THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

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US targets Chinese companies with sanctions aimed at starving DPRK of funds

July, 2017

Chinese bank and shipping company among those designated for North Korea ties.

US targets Chinese companies with sanctions aimed at starving DPRK of funds

The US Department of the Treasury’s Financial Crimes Enforcement Network (‘FinCEN’) has announced a proposed rule for a special measure that would impose anti-money laundering sanctions against China’s Bank of Dandong for alleged links to companies involved in financing North Korea (‘DPRK’)’s nuclear and ballistic missile programmes (29 June). The Bank of Dandong is considered to be a financial institution of ‘primary money laundering concern’ under s311 of the USA PATRIOT Act.

The special measure is designed to restrict the Bank of Dandong from accessing the US and international financial systems and conducting worldwide transactions in US dollars. This is only the second time the US has sanctioned a Chinese business; in September 2016 industrial machinery company Dandong Hongxiang Industrial Development Co and four Chinese officials were designated for alleged ties to DPRK’s nuclear and ballistic programmes.

In a co-ordinated action, the US Treasury’s Office of Foreign Assets Control (‘OFAC’) sanctioned one Chinese business, Dalian Global Unity Shipping Co, and two Chinese individuals, Sun Wei and Li Hong Ri, with alleged connections to DPRK.

US Treasury Secretary Stephen Muchnin said:

‘While today’s actions are directed at Chinese individuals and entities, we look forward to continuing to work closely with the Government of China to stop illicit financing involving North Korea. We are in no way targeting China with these actions.’

The escalation of DPRK’s weapons programme marked by the test of an intercontinental ballistic missile on 4 July has raised the prospect of further sanctions targeting parties in China and other countries which enable the financing of the regime.

 

For FinCEN’s notice see:
https://www.fincen.gov/sites/default/files/federal_register_notices/2017-06-29/NPRM_311Dandong_0.pdf

For the US Treasury’s announcement see:
https://www.treasury.gov/press-center/press-releases/Pages/sm0119.aspx

For OFAC’s designations see:
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20170629.aspx

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