OFAC’s Specially Designated Nationals List Update



Last week Steph Haggard commented on Executive Order 13722 that outlined new guidelines for North Korea sanctions enforcement. The guidelines include additions to the Treasury Department’s list of Specially Designated Nationals (SDN), which are searchable on the Treasury Department’s Office of Foreign Assets Control (OFAC) website. We focus on the DPRK-related SDN lists but the the website contains SDN information for various other countries and is a useful source for tracking official US government sanctioned individuals, entities, and vessels.

OFAC’s mission statement:

“The Office of Foreign Assets Control (OFAC) of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States. OFAC acts under Presidential national emergency powers, as well as authority granted by specific legislation, to impose controls on transactions and freeze assets under US jurisdiction. Many of the sanctions are based on United Nations and other international mandates, are multilateral in scope, and involve close cooperation with allied governments.”

Among other sanctioned country designations, the OFAC database includes SDN lists from three executive orders pertaining to North Korea sanctions and a more general non-proliferation of weapons of mass destruction (NPWMD) list. From the executive orders there are 33 entities, 25 individuals, and 39 vessels included on the SDN list. The more broad NPWMD SDN list includes an additional 66 DPRK-specific individuals and entities. (For NPWMD designations the actual number could be higher since some of the entities and individuals are engaging in proliferation activities with Iran or Syria and North Korea). The first two executive orders added senior officials, including Kim Yong Chol and Hwang Pyong So, as well as institutions such as the Central Military Commission of the Korean Worker’s Party, General Reconnaissance Bureau, Office 39, and the National Defense Commission, as well as various North Korean corporations, banks, and ships. Executive Order 13722 added to the list 11 new vessels and 15 entities; the entities are mostly shipping and trading companies, but also includes the KWP’s Propaganda and Agitation Department. The NPWMD list includes entities and individuals related to WMD.

The OFAC list is in full compliance with UN designations of vessels, which included this category for the first time in UNSCR 2270. The obligation of states to interdict North Korean vessels and the designation of specific vessels were some of the strictest measures in the resolution. Physically interdicting a vessel is more visible than enforcing—or not enforcing—banking or trade sanctions. After the resolution passed we have already seen two interdictions by the Philippines. For China, allowing vessel designation in 2270 was significant yet it remains to be seen if China will support the strict enforcement of these sanctions. In fact, China successfully lobbied the US last week to remove four vessels from the UN list, one of which was one of the ships detained by the Philippines.

Comparing the total number of OFAC designations with those in UNSCR 2270 and previous UNSC-related designations shows that the US has a much longer list (160 compared to 71). The recent OFAC additions were included to keep the US in compliance with international law and now almost every UN designation is listed by OFAC. The notable exceptions are two individuals named in the UN’s 1718 Committee July 2009 report: Hwang Sok-hwa, Director in the General Bureau of Atomic Energy; and Han Yu-ro: Director of Korea Ryongaksan General Trading Corporation. If anyone can figure out why these individuals don’t appear on the OFAC SDN list we’d be curious to know.

Treasury OFAC SDN lists taken from three executive orders and NPWMD designations:

Executive Order 13551 (September 2010)— Blocking Property of Certain Persons With Respect to North Korea. (searchable as “DPRK”).

Executive Order 13687 (January 2015)— Imposing Additional Sanctions With Respect To North Korea.(searchable as “DPRK2”).

Executive Order 13722 (March 2016)— Blocking Property of the Government of North Korea and the Workers’ Party of Korea, and Prohibiting Certain Transactions With Respect to North Korea. (searchable as “DPRK3”).

Non-proliferation of Weapons of Mass Destruction Regulations (searchable as “NPWMD”).

UN Sanctions Designations:

UN Security Council Resolution 2270 (this is the only UNSCR with a designations list in the text)

1718 Security Council Committee Letter (April 2009)

1718 Security Council Committee Letter (July 2009)

1718 Security Council Committee Letter (May 2012)

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