On November 19, 2020, the US Department of the Treasury sanctioned two entities for participating in the exportation of North Korean citizens to perform forced labor. According to the Treasury, North Korea supports its weapons development program with revenue from the labor of North Korean citizens sent to work abroad in “grueling conditions.” These sanctions are imposed pursuant to Executive Order 13722 of March 2016, and in the spirit of the North Korea Sanctions and Policy Enhancement Act of 2016, including as amended by the Otto Warmbier Banking Restrictions Involving North Korea Act, which requires the imposition of sanctions against anyone who knowingly participates in the export of North Korean workers in a manner than generates significant revenue to the North Korean regime.
In a related action, the Treasury Department updated names and locations for three additional entities that were previously designated under Executive Order 13722, for their participation in the export of North Korean workers. These three companies are responsible for sending workers to Russia and China.
As a result of these designations, US property belonging to these individuals and entities is blocked, and transactions and dealings with them are generally prohibited. In addition, anyone who engages in transactions with a designated person or entity may be exposed to sanctions.