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The US was quick to announce actions it was taking in compliance with the UNSC Resolution 2087. The Treasury announcement contained one interesting detail and raises a question for policy with respect to China.
Ra Ky'ong-Su, one of the designated individuals, is the Tanchon Commerical Bank (TCB) Representative “to Beijing”; similarly Kim Kwang-Il is identified as the TCB Deputy Representative “to Beijing.” TCB had already been designated pursuant to E.O. 13382 in October 2009 because it acts as the financial arm of Korea's Mining Development Trading Corporation (KOMID). For example, according to Treasury TCB was involved in ballistic missile transactions from KOMID to Iran's Shahid Hemmat Industrial Group (SHIG), also a UN designated entity. For its part, KOMID was designated under E.O. 13382 in 2005 and by the UNSCR 1718 Committee in 2009. KOMID has offices in multiple countries around the world and facilitates weapons sales and procurement.
The question: if these two individuals are representatives “to” Beijing, is the sanction targeting them or should it rightly target any individual who occupies these roles? It certainly sounds to us like the Beijing offices or activities of these individuals play a role in North Korean proliferation activities. Is China going to allow this activity to take place on its soil?
On the other hand, we were intrigued by the targeting of Leader (Hong Kong) International Trading Limited. First, it shows the role of third parties in facilitating the shipment of machinery and equipment to customers on behalf of KOMID and directly to KOMID representatives located outside of North Korea. But second, the Chinese must have acquiesced on this designation, since it is the only non-North Korean entity or individual targeted. Was this a signal?
The State Department announcement designated one entity and two individuals under Executive Order 13382: the Korean Committee for Space Technology (KCST), KCST senior official Paek Chang-Ho, and General Manager of the Sohae Satellite Launching Station Chang Myong-Chin.
