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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:

The following entities have been added to OFAC’s SDN List:
DANDONG RICH EARTH TRADING CO., LTD., Jiadi Square, Number 64, Binjiang Middle Road, Room 1001, Building B, Dandong City, Liaoning, China [NPWMD] (Linked To: KOREA KUMSAN TRADING CORPORATION).
DANDONG TIANFU TRADE CO., LTD. (Chinese Simplified: 丹东天富贸易有限公司), No. 5, Shiwei Road, Zhenxing District, Dandong City, China [DPRK3].
DANDONG ZHICHENG METALLIC MATERIAL CO., LTD. (Chinese Simplified: 丹东至诚金属材料有限公司) (a.k.a. DANDONG CHENGTAI; a.k.a. DANDONG CHISONG METAL MATERIALS COMPANY; a.k.a. DANDONG ZHICHENG METAL MATERIALS CO., LTD; a.k.a. DANDONG ZHICHENG METALLIC MINERAL CO., LIMITED), Dandong, Liaoning, China [DPRK3].
GEFEST-M LLC, Office 401, Structure 1, Building 1, Chermyanskaya Street, Moscow 127081, Russia; Office Space 5, Room 18, Building 5/7 Rozhdestvenka Street, Moscow 107031, Russia [NPWMD] (Linked To: KOREA TANGUN TRADING CORPORATION).
JINHOU INTERNATIONAL HOLDINGS CO., LTD. (Chinese Simplified: 金猴集团国际控股有限公司), No. 106, Heping Road, Weihai, Shandong, China [DPRK3].
MANSUDAE OVERSEAS PROJECTS ARCHITECTURAL AND TECHNICAL SERVICES (PTY) LIMITED, Namibia; Registration ID 2001/044 (Namibia) [DPRK3] (Linked To: MANSUDAE OVERSEAS PROJECT GROUP OF COMPANIES).
MINGZHENG INTERNATIONAL TRADING LIMITED, Flat/RM A30 9/F, Silvercorp International Tower, 707-713 Nathan Road, Kowloon, Mong Kok, Hong Kong; 224-4 Shifa Da Lu, RM 1305, Heping District, Shenyang City, Liaoning Province, China [NPWMD] (Linked To: FOREIGN TRADE BANK OF THE DEMOCRATIC PEOPLE’S REPUBLIC OF KOREA; Linked To: SUN, Wei).
QINGDAO CONSTRUCTION (NAMIBIA) CC, ERF 338, Platinum Street, Prosperita, Windhoek, Namibia; P.O. Box 26774, Windhoek, Namibia; Registration ID 2008/0598 (Namibia) [DPRK3] (Linked To: MANSUDAE OVERSEAS PROJECTS ARCHITECTURAL AND TECHNICAL SERVICES (PTY) LIMITED; Linked To: MANSUDAE OVERSEAS PROJECT GROUP OF COMPANIES).
TRANSATLANTIC PARTNERS PTE. LTD., 10 Anson Road, #29-05A, International Plaza 079903, Singapore [DPRK3].
VELMUR MANAGEMENT PTE LTD, 2 Marina Blvd., No. 66-08, The Sail at Marina Bay 018987, Singapore [DPRK3] (Linked To: TRANSATLANTIC PARTNERS PTE. LTD.).
The following individuals have been added to OFAC’s SDN List:
 
CHI, Yupeng, Room 301, Unit 1, No. 129 Jiangcheng Street, Yuanbao District, Dandong City, Liaoning Province, China; DOB 22 May 1969; nationality China; Gender Male; Passport E27979708 (China); National ID No. 210602196905220510 (China); Chairman and Majority Owner, Dandong Zhicheng Metallic Material Co., Ltd. (individual) [DPRK3] (Linked To: DANDONG ZHICHENG METALLIC MATERIAL CO., LTD.).
 
HUISH, Irina Igorevna, Russia; DOB 18 Jan 1973; Gender Female (individual) [DPRK3] (Linked To: VELMUR MANAGEMENT PTE LTD).
 
KIM, Tong-chol, 34 Herbst Street, Windhoek, Namibia; DOB 07 Aug 1968; POB North Korea; Gender Male; Passport 472336944 issued 10 Sep 2012 expires 10 Sep 2017; Managing Director, Mansudae Overseas Projects; Director, Mansudae Overseas Projects Architectural and Technical Services (PTY) Ltd.; Deputy Managing Director, Qingdao Construction (Namibia) CC (individual) [DPRK3] (Linked To: MANSUDAE OVERSEAS PROJECT GROUP OF COMPANIES; Linked To: MANSUDAE OVERSEAS PROJECTS ARCHITECTURAL AND TECHNICAL SERVICES (PTY) LIMITED; Linked To: QINGDAO CONSTRUCTION (NAMIBIA) CC).
 
KIRAKOSYAN, Ruben Ruslanovich, Russia; DOB 03 Mar 1980; citizen Russia; Gender Male (individual) [NPWMD] (Linked To: GEFEST-M LLC; Linked To: KOREA TANGUN TRADING CORPORATION).
 
PISKLIN, Mikhail Yur’evich, Russia; DOB 01 Dec 1980; Gender Male; Passport 71 0588176 (individual) [DPRK3].
 
SERBIN, Andrey, Russia; DOB 01 Nov 1986; Gender Male (individual) [DPRK3].
 

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.

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