On November 19, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) designated two entities operating in Russia determined to be involved in the exportation of forced labor from North Korea, under the authority of Executive Order (E.O.) 13722 of March 15, 2016, “Blocking Property of the Government of North Korea and the
North Korea Sanctions
OFAC Issues Fact Sheet Regarding Humanitarian Trade Involving Sanctioned Countries and Provides COVID-19 Guidance
In response to criticism that sanctions are hampering the global response to the COVID-19 pandemic, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released new guidance to encourage those interested in humanitarian trade involving jurisdictions sanctioned by the United States to “avail themselves of longstanding exemptions, exceptions, and authorizations” pertaining to that…
OFAC Puts Shipping Community on Notice with Updates and Expanded Guidance
Over the last week, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued two updated advisories, as well as issued a series of new designations of Specially Designated Nationals (SDNs), highlighting the sanctions-related risks for, and the focus on, the shipping community. Taken together, they provide important guidance for…
Importer Settles Potential Civil Liability for Apparent Violations of the OFAC North Korea Sanctions Regulations
On January 31, 2019, e.l.f. Cosmetics, Inc. (“ELF”) agreed to pay $996,080 to settle its potential civil liability for 156 apparent violations of the North Korea Sanctions Regulations (NKSR). Elf is a cosmetics company headquartered in Oakland, California.

ELF appeared to have violated § 510.201(c)1 of the NKSR by…
Forced Labor: The Interplay Between Sanctions and Customs Compliance in the Context of the Democratic People’s Republic of Korea (DPRK)
As a consequence of U.S. and UN sanctions on the Democratic People’s Republic of Korea (DPRK or North Korea), companies increasingly need to coordinate compliance efforts across the typically distinct worlds of economic sanctions and import/customs compliance. This is particularly necessary with respect to identifying, and mitigating the risk of DPRK-related labor in supply…
Now Available On Demand – Webinar Trade in 2018 – What’s Ahead?
On April 19, Crowell & Moring’s International Trade Attorneys hosted a webinar on “Trade in 2018 – What’s Ahead?”
Please click here to register and view the webinar on demand.
Summary
From the Section 232 national security tariffs on steel and aluminum imports to the ongoing NAFTA re-negotiation, the Trump administration is seeking to implement…
OFAC AMENDS AND REISSUES NORTH KOREA SANCTIONS REGULATIONS
In the Federal Register on March 5, OFAC amended and reissued the North Korea Sanctions Regulations in its entirety to implement three recent Executive Orders and to reference the North Korea Sanctions and Policy Enhancement Act of 2016 and the Countering America’s Adversaries Through Sanctions Act.
The agency is also incorporating into the reissue:
- Several
…
North Korean Labor Remains Problematic for Global Supply Chains
Despite increased pressure from the U.S. and the UN Security Council, human rights groups estimate about 16 countries still host North Korean laborers. A recent estimate by the Korea Institute for National Unification in Seoul puts the number of North Korean workers overseas at around 147,000. Most work in China and Russia, but reports…
New U.S. and UN Sanctions Increase Pressure on Non-U.S. Persons Transacting with North Korea
On September 20, 2017, President Trump signed Executive Order 13810, which substantially increases the authority of the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) to impose both primary and secondary sanctions on non-U.S. persons transacting with the Democratic People’s Republic of Korea (aka North Korea). These new sanctions come soon after,…
President Trump Signs Substantial Expansion Of Sanctions On Russia, Iran, And North Korea
On August 2, President Trump signed into law the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA), which imposes new sanctions on Russia, Iran, and North Korea.
While President Trump noted his view that the legislation was “significantly flawed”, its passage represents the successful culmination of months of Congressional negotiations and its provisions…