On September 11, 2020, the US Department of Justice filed a complaint against Ryer International Trading Limited and Rensy International Trading Co., Limited, for the forfeiture in rem of nearly $1 million, amidst allegations that the companies acted as intermediaries for ZTE and other known North Korean financial facilitators, to purchase telecommunications equipment, including US-origin equipment, on behalf of North Korea.
According to the complaint, an investigation by the Federal Bureau of Investigation uncovered a scheme by sanctioned North Korean banks to launder US dollars through the US using a host of front companies in order to evade US sanctions. In 2017, ZTE entered a guilty plea and settled charges with the US Department of Commerce and the US Department of the Treasury’s Office of Foreign Assets Control (OFAC), agreeing to pay over $892 million in fines for sanctions violations. During the government’s investigation of ZTE, they learned of front companies, Ryer and Rensy, that ZTE frequently used to bypass sanctions.
Between 2010 and 2015, Ryer and Rensy allegedly transferred millions US dollars on behalf of North Korea in violation of the International Emergency Economic Powers Act (IEEPA) and federal money laundering statues; Ryer and Rensy never sought or obtained an OFAC license for any of their transactions. The government requests that the defendants forfeit a total of $955,880.85, for proceeds traceable to the IEEPA violations.
Consequently, this forfeiture action was the last action filed by Assistant US Attorney, and former Willkie Farr & Gallagher LLP associate, Zia Faruqui before his swearing-in as a Magistrate Judge for the District Court for the District of Columbia.