On August 22, 2017, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a new round of designations targeting certain Chinese and Russian entities and individuals for their North Korean activities.  This unilateral step comes just a couple of weeks after the United Nations Security Council, backed by China and Russia, imposed strict new sanctions on North Korea in the wake of its testing of two functional intercontinental ballistic missiles (ICBMs).  Further, this comes on the heels of the ensuing threats of war between President Donald J. Trump and North Korean dictator Kim Jung Un.   There appears to be no question that the U.S. administration perceives the North Korean threat to be imminent, requiring swift action against those supporting the rogue regime.

Specifically, OFAC’s action is the result of findings that the following entities and individuals have been involved in supporting North Korea’s nuclear missile development program:

Conclusion

OFAC imposed these sanctions against the ten companies and six individuals for various reasons. Those reasons included providing North Korea with materials for weapons, facilitating the export of North Korean workers, buying coal and other resources that generate cash for Pyongyang, and helping companies in North Korea gain access to the US financial system. The U.S. Department of Treasury has taken these swift “secondary sanctions” to prevent third-country actors from helping Kim Jung Un’s regime from developing weapons of mass destruction. Moreover, for those companies that might contemplate helping North Korea evade sanctions, they are now on notice to expect to be barred from the US financial system. The Trump administration has firmly signaled a tough stance through its willingness to impose unilateral secondary sanctions at the drop of a hat.