Additional Sanctions with Respect to North Korea

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President Trump issued Executive Order 13722 (E.O. 13722), effective September 21, 2017, imposing additional sanctions with respect to North Korea. Previously all property and interests in property of the Government of North Korea and the Workers’ Party of Korea had been blocked.

E.O. 13722 blocks all property and interests in property, prohibiting exports, transfers, payments, withdrawals, or other dealing with persons:

  1. who operate in the construction, energy, financial services, fishing, information technology, manufacturing, medical, mining, textiles, or transportation industries in North Korea;
  2. who own, control, or operate any port in North Korea, including any seaport, airport, or land port of entry;
  3. who engage in at least one significant importation from or exportation to North Korea of any goods, services, or technology;
  4. any North Korean person, who engage in commercial activity that generates revenue for the Government of North Korea or the Workers’ Party of Korea;
  5. who materially assist, sponsor, or provide financial, material, or technological support for goods or services in support of any persons whose property and interests in property are blocked; or
  6. who own or are controlled by, or act on behalf of, any person whose property and interests in property are blocked.

Additional sanctions imposed include:

  • Several new designation criteria established;
  • Prohibits entry into the U.S. of aircraft or vessels that have called or landed at a port or place in North Korea in the previous 180 days; or vessels that engaged in ship-to-ship transfers with such a vessel in the previous 180 days;
  • Provides authority to block funds transiting accounts linked to North Korea from the U.S.; and
  • Provides authority to impose sanctions on a foreign financial institution that knowingly conduct or facilitate transactions on behalf of blocked persons, or in connection with trade with North Korea.

The Office of Foreign Assets Control (OFAC) issued notice of these sanctions, and updated their Frequently Asked Questions on North Korea related sanctions.

These additional sanctions are the result of continued threat to the national security, foreign policy, and economy of the U.S by North Korea.

If you have any questions regarding Additional North Korean Sanctions, Livingston can help! Please contact either your Livingston account manager or our regulatory affairs department at usregaffairs@livingstonintl.com.