Sanctions Roundup II: OFAC License Requests
Thanks to Peter Hayes, we were alerted to a website called governtmentattic.org which releases information secured through Freedom of Information Act requests. In this interesting batch of documents, Governmentattic requested the first five pages of all applications to the Office of Financial Assets Control for a license to do business with North Korea. In addition to showing the complexity of the licensing regime, a number of the requests show the supply chains, humanitarian operations and other speculative ventures that are emerging in the country:
- Barnabas Trading Co. was seeking to import shoes from a joint venture between Rason Industrial Company, clearly a state-owned enterprise, and a Chinese-based firm owned by two Americans.
- Printer Essentials, an importer and wholesaler, was seeking permission to import South Korean cartridges that were made using North Korean labor through a redacted firm, presumably in China.
- Korea Pyongyang Trading wants to import North Korean beer; Marc Noland profiled Steve Park, the man behind this mission, in an earlier post. Other firms sought permission to import small quantities of columbite—a mineral—and stamps.
- By far our favorite, two requests asked for permission to import a single pair of Noko jeans. Noko Jeans is a Swedish firm that manufactured jeans at a Pyongyang facility. With a $220 price tag, we are probably talking about some serioius mark ups. Spiegel online covered the strange story of this little start-up in a piece called “Dictatorship Denim” back in 2010. The project became a cause celebre in Sweden and ultimately folded, with the dying embers of the effort visible on Twitter.
A number of requests had to do with financial services.
- Carbon Development and Trading, was seeking permission to trade in trading of certified emission reduction credits under the Clean Development Mechanism established under the Kyoto protocol.
- Several law firms were seeking permission to provide advice to clients about intellectual property issues in North Korea; the business proposition involved a possible hiring of local agents on the firm’s behalf. Could Disney be going after illegal use of Mickey? Intel also filed an IP-related request.
- Several communications from banks centered on blocked funds, but in a particularly interesting request JP Morgan Chase inquired about its ability to trade in futures markets in China that might involve gold contracts for which North Korea was a supplier.
Finally, the Eugene Bell Foundation had to go through an approval process for a purely humanitarian effort that involved testing of samples for its tuberculosis efforts. Similarly, an American government selling sprayers asked if these could be resold for humanitarian purposes. If further sanctions do move ahead, we sincerely hope they are cautious with respect to humanitarian activities such as Bell's.