Sanctions, NGOs, and Whack-a-Mole

Marcus Noland (PIIE)



The intelligence community engages in a thankless task of tracking and exposing sanctions evasion schemes, at the level of enforcement a surely frustrating game of “whack-a-mole.” Within the US government, the placement of individuals and entities on sanctions lists is constrained by the need to preserve sources and methods. The public listings are the proverbial tip of the iceberg. 

That process is repeated around the world, so by the time one gets to the UN Security Council lists, which amount to the intersection of the target lists that individual governments are willing to reveal, one is truly working with the tip of the iceberg. The cumbersomeness of this process impedes effective sanctions enforcement.

By putting their results into the public domain, [private researchers] relieve the IC from the burden of revealing what they know.

That conundrum is one reason that recent work by private researchers is so exciting: by putting their results into the public domain they in effect relieve the IC from the burden of revealing what they know. Work by C4ADS is exemplary of this trend.

In the past month, we have been graced by two more examples of private sector sleuthing, both published at Arms Control Wonk. The first was an extraordinary piece by Daniel Salisbury documenting how a small Malaysian shipbuilding firm, Kay Marine Sdn Bhd, which the US listed last year, is apparently acting as a sales front for a variety North Korean military vessels, including submarines(!). The post even includes links to the company’s promotional videos which show the North Korean vessels racing around to the accompaniment of Joe Satriani shredding. (Wonder if he got any royalties?)

If this wasn’t enough, Andrea Berger followed up with a piece on how Malaysia-based Malaysia-Korea Partners (MKP) has gotten into the mercenary private security business, creating a joint venture with Omega Risk Solutions, an outfit run by former South African National Defense Forces soldiers to provide armed security in Africa. According to Berger, the MKP-Omega JV may include the United Nations (you read that right) among its clients. To be clear the allegation is not that the UN has hired North Koreans to guard its facilities in Africa, but that depending on whether the contract was with Omega or the MKP-Omega partnership, the UN may have hired a North Korea-owned firm to provide security. Talk about the right hand not knowing what the left is doing.

In short, private researchers are putting more grist into the mill for the official sanctions committee, or at a minimum, giving the IC cover.

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