The US Treasury’s Financial Crimes Enforcement Network (FinCEN) has determined that China-based Bank of Dandong is serving as a gateway for North Korea to access the US and international financial systems, in circumvention of sanctions. It has proposed introducing a rule under the US PATRIOT Act that would require US banks to ensure that Bank of Dandong does not access the US financial system directly or indirectly through other foreign banks. The proposed rule is available here, with a 60-day comment period.
In addition, OFAC has designated Chinese citizens Sun Wei and Li Hong Ri. Sun Wei is said to have been closely aligned with US-designated Foreign Trade Bank, North Korea’s primary foreign exchange bank, in establishing and running a cover company on its behalf. Li Hong Ri is said to have cooperated with US-designated person Ri Song Hyok, official for designated Koryo Bank, to create front companies used to procure items and conduct financial transactions on behalf of North Korea. It has also designated Dalian Global Unity Shipping Co., a large freight company operating in North Korea, for smuggling luxury goods in violation of UN sanctions. The details of the listings are here.
Maya Lester QC is a senior barrister (Queen’s Counsel) at Brick Court Chambers with a wide-ranging practice in public law, European law, competition law, international law, human rights & civil liberties. She has a particular expertise in sanctions. The legal directories say she is the...See profile for Maya Lester QC >