Sanctions Round Up First Quarter 2022

Shearman & Sterling LLP

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7 NORTH KOREA North Korea made headlines this quarter after it announced that it had tested in late March a new intercontinental ballistic missile. The launch drew condemnation from leaders worldwide and ended a self-imposed moratorium on long-range testing the regime put in place in 2017. The launch follows several North Korea-related actions this quarter focused on its missile development and nuclear capabilities. US Targets North Korea's Procurement of Missile-Related Inputs In the first action targeting persons for allegedly having procured goods for the DPRK's weapons of mass destruction and ballistic missile programs, the US on January 12 designated five North Korean individuals pursuant to E.O. 13382: one Russia-based DPRK national, Choe Myong Hyon; and four China-based DPRK nationals, Sim Kwang Sok, Kim Song Hun, Kang Chol Hak, and Pyon Kwang Chol. Each was designated for providing telecommunications equipment, software, chemicals, and steel alloys in support of the Second Academy of Natural Sciences, a sanctioned entity involved in the DPRK's weapons programs. In a related action, the State Department designated North Korean national O Yong Ho, Russian national Roman Anatolyevich Alar, and Russian entity Parsek LLC, also for having contributed to North Korea's weapons programs. On March 11, OFAC then designated two individuals and three entities for their assistance to Pak Kwang Hun, an SDN well-known for his efforts to acquire materiel for the DPRK defense industry. OFAC designated Russian entity Apollon OOO and its director, Aleksandr Andreyevich Gayevoy, for employing Pak Kwang Hun using an alias, to deceive suppliers that the end-user of their goods was North Korea. Pak Kwang Hun is also alleged to have worked with Russian company Zeel – M Co., Ltd and its director, Aleksandr Aleksandrovich Chasovnikov, to procure defense equipment for the DPRK. According to OFAC, Chasovnikov coordinated the purchase and transportation of defense-related items for other DPRK organizations.

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