Primary Sanctions

The North Korea Sanctions Regulations (NKSR) prohibit, among other things:

  • the export, reexport, sale or supply, directly or indirectly, from the US or by a US person, wherever located, of any goods, technology, or services to North Korea; and
  • the facilitation by a US person of transactions by a foreign person that the US person would otherwise be prohibited from engaging in under the NKSR.

Secondary Sanctions

Executive Order 13,810 authorizes the Secretary of the Treasury:

  • to block the property of any person trading goods or services with North Korea;
  • to impose sanctions on foreign financial institutions that knowingly conduct or facilitate certain transactions with North Korea; and
  • to block funds linked to bank accounts identified by the Secretary of the Treasury as being owned or controlled by a North Korean person.

Executive Order 13,810 further provides the Secretary of the Treasury with the authority to designate any person the Secretary determines to be engaged in certain activity involving North Korea, including certain commercial activity.1  Specifically, the Secretary of the Treasury is authorized to block anyone the Secretary determines to:

  • operate in the construction, energy, financial services, fishing, information technology, manufacturing, medical, mining, textiles, or transportation industries in North Korea;
  • own, control, or operate any port of entry in North Korea;
  • have engaged in at least one significant importation from or exportation to North Korea of any goods, services, or technology;
  • be a North Korean person; OR
  • have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person designated pursuant to the Executive Order, or to be owned or controlled, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to the Executive Order.

1 Exec. Order No. 13,810, 82 Fed. Reg. 44705 (Sept. 20, 2017).

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