U.S. Issues Sanctions Risks for Businesses with N. Korean Supply Chain Links

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Saturday, July 28, 2018
Author: 
Bruce Zagaris
Volume: 
34
Issue: 
8
Abstract: 

On July 23, 2018, the U.S. Department of State, with the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Homeland Security’s (DHS) Customs and Border Patrol (CBP) and Immigration and Customs Enforcement (ICE), issued an advisory to high sanctions evasions tactics used by North Korea that could expose businesses – including manufacturers, buyers, and service providers – to sanctions compliance risks under U.S. and/or U.N. sanctions authorities.  The advisory also helps businesses in complying with the requirements under Title III, the Korean Interdiction and Modernization of Sanctions Act of the Countering America’s Adversaries through Sanctions Act (CAATSA).  The advisory warns businesses to be aware of deceptive practices employed by North Korea in order to implement effective due diligence policies, procedures, and internal controls to ensure compliance with applicable legal requirements across their entire supply chains.