The United States Department of Treasury Office of Foreign Assets Control (“OFAC”), as part of their removal of North Korea as a sanctions program has removed some entities from the bottom of the SDN list.

The following entities have been removed:

CHOSUNBOHOM (a.k.a. KOREA FOREIGN INSURANCE COMPANY), 123, Rue des Tennerolles, 92210 Saint-Cloud, Paris, France [NORTH KOREA]

KOREA FOREIGN INSURANCE COMPANY (a.k.a. CHOSUNBOHOM), 123, Rue des Tennerolles, 92210 Saint-Cloud, Paris, France [NORTH KOREA]

CHOSUNBOHOM (a.k.a. KOREA FOREIGN INSURANCE COMPANY), Berlin Glinkastrasse 5 1080, Germany [NORTH KOREA]

KOREA FOREIGN INSURANCE COMPANY (a.k.a. CHOSUNBOHOM), Berlin Glinkastrasse 5 1080, Germany [NORTH KOREA]

CHOSUNBOHOM (a.k.a. KOREA FOREIGN INSURANCE COMPANY), Unt. Batterieweg 35, CH-4008 Basel, Switzerland [NORTH KOREA]

KOREA FOREIGN INSURANCE COMPANY (a.k.a. CHOSUNBOHOM), Unt. Batterieweg 35, CH-4008 Basel, Switzerland [NORTH KOREA]

COMPANIA DE COALICION DEL COMERCIO DE COREA, S.A., Panama [NORTH KOREA]

A while back OFAC had issued a final rule that amended Appendix A to 31 C.F.R. chapter V to reflect the removal of North Korea as a sanctions program. However, this does not mean that sanctions are terminated for that country. The final rule makes note of the fact that “all property and interests in property of North Korea or a North Korea national that were blocked as of June 16, 2000, and remained blocked immediately prior to June 26, 2008, nevertheless remains blocked pursuant to Executive Order 13466.”

As I, and a number of other OFAC lawyers, have stated in the past, broad country based sanctions like the Iranian Transactions Regulations and the former North Korea Sanctions are ineffective and should be replaced with smarter sanctions that target persons involved in certain activities. I’m glad to see the North Korea sanctions go and I think OFAC is doing the right thing in phasing out some of these country based sanctions programs.