North Korea: Shipping and Supply Chain Risks and Risk Mitigation
Author: Mario Mancuso.; Sanjay Mullick.; Jeremy Iloulian.
Source: Volume 35, Number 03, March 2019 , pp.37-44(8)
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Abstract:
In 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published two advisories, both related to North Korea’s sanctions evasion tactics. The advisories identified risks for companies specifically related to shipping and supply chains, potential indicators of a North Korean nexus, and how to mitigate such risks. The authors discuss these advisories, their impact and implications for both U.S. and non-U.S. parties, and how OFAC expects companies to comply.Keywords: U.S. Sanctions on North Korea; International Emergency Economic Powers Act (“IEEPA”); OFAC Advisory on Shipping; OFAC Advisory on Supply Chain Links
Affiliations:
1: Kirkland & Ellis LLP; 2: Kirkland; 3: Kirkland.